Public Hearing - December 9, 2021

    


 1      BEFORE THE NEW YORK STATE SENATE
        STANDING COMMITTEE ON ETHICS AND INTERNAL GOVERNANCE
 2      ------------------------------------------------------

 3                        PUBLIC HEARING:

 4             TO DISCUSS NEW YORK STATE’S SYSTEM OF

 5               ETHICS OVERSIGHT AND ENFORCEMENT

 6
        ------------------------------------------------------
 7
                                   Senate Hearing Room
 8                                 250 Broadway
                                   New York, New York
 9
                                   Date:  December 9, 2021
10                                 Time:  10:00 a.m.

11
        PRESIDING:
12
           SENATOR ALESSANDRA BIAGGI
13         Chair

14         SENATOR LIZ KRUEGER
           Co-Sponsor
15

16      PRESENT:

17         SENATOR GEORGE BORRELLO

18         SENATOR PHIL BOYLE

19         SENATOR BRAD HOYLMAN

20         SENATOR ANTHONY PALUMBO

21

22

23

24

25







                                                             2
 1
        SPEAKERS:                               PAGE  QUESTIONS
 2
        Nelson Sheingold                          12      17
 3      Counsel to the NYS Comptroller
        Terri Crowley                             12      17
 4      Executive Deputy Comptroller
          for Operations
 5      New York State

 6      Rachael Fauss                             67      84
        Senior Research Analyst
 7      Reinvent Albany

 8      Blair Horner                              67      84
        Executive Director
 9      New York Public Interest Research Group

10      Ben Weinberg                              67      84
        Director of Public Policy
11      Citizens Union

12      Scott Wiener                             131     137
        California State Senator
13      Chair of Senate Legislative
          Ethics Committee
14
        Erin Peth                                131     137
15      Chief Counsel
        California State Senate,
16        Committee on Legislative Ethics

17      Robert Tembeckjian                       171     182
        Administrator & Counsel
18      Judicial Conduct Commission

19

20

21

22

23

24

25







                                                             3
 1             SENATOR BIAGGI:  Okay.

 2             All right.  Good morning, everybody.

 3             I am State Senator Alessandra Biaggi, as well

 4      as the chairwoman of the Senate Committee on Ethics

 5      and Internal Governance.

 6             And I would like to thank everybody who is

 7      participating today and present today for being here

 8      in our second of the ethics hearings this year.

 9             I want to acknowledge and thank

10      Senator Liz Krueger for co-chairing today's hearing,

11      as well as members of the Senate Ethics Committee,

12      including Ranking Member Senator Palumbo, who will

13      be here shortly; and my colleagues Senator Boyle and

14      Borrello for joining us today.

15             I would also like to express my gratitude to

16      leader and -- excuse me -- to the leader of the

17      Senate Majority Conference, Andrea Stewart-Cousins,

18      for supporting, and continuing to support, the

19      Ethics Committee, and calling this hearing today.

20             We are here, as I mentioned, for our second

21      hearing of the year; specifically, to examine

22      New York's system of ethics, oversight, and

23      enforcement, to identify areas of needed

24      improvement, and to discuss alternative approaches

25      to enforcing ethics within our state government,







                                                             4
 1      something that I think many people are interested in

 2      across the state.

 3             Earlier this year the committee convened for

 4      a hearing just a few days into the new executive

 5      administration, examining the role of the Joint

 6      Commission on Public Ethics, or, "JCOPE," as we all

 7      refer to it, and its failure to serve as an

 8      independent ethics body.

 9             We heard directly from the executive director

10      of JCOPE, Sanford Berland; former JCOPE Commissioner

11      Director Julie Garcia; and various good-government

12      groups.

13             We were also joined by legislators from

14      Alaska and Rhode Island who outlined effective

15      systems of ethics oversight within our own

16      governments.

17             The testimony from our first hearing

18      identified key areas for improvement within JCOPE,

19      and subsequent legislative solutions to reform the

20      commission, and to restructure an entirely new

21      ethics oversight body, which we hope to do through

22      Senator Krueger's bill.

23             The purpose of today's hearing is to examine

24      the work of government agencies and offices beyond

25      JCOPE who are tasked with ethics and anticorruption







                                                             5
 1      work in New York, and to identify areas of

 2      improvement and legislative solutions within these

 3      bodies.

 4             This hearing will also discuss

 5      Governor Kathy Hochul's new transparency and ethics

 6      policies, and identify additional areas for reform

 7      from the executive.

 8             During today's hearing, we are joined by

 9      representatives of Comptroller Thomas DiNapoli's

10      office, Nelson Sheingold, counsel to the

11      New York State Comptroller; and Terri Crowley,

12      executive deputy comptroller for operations.

13             We will also hear from good-government

14      groups, and California State Senator Scott Wiener

15      who chairs the California Senate Legislative Ethics

16      Committee.

17             And many of you might know him because of his

18      work also in housing across the state of California.

19             Before we begin, it's very important just to

20      take a note of the offices that are absent from

21      today's hearings.

22             And let the record reflect that the committee

23      invited the new chair of JCOPE, Jose Nieves, to

24      testify, who was appointed by Governor Hochul to

25      replace Commissioner James Dering.







                                                             6
 1             Additionally, we invited the principal

 2      representatives from the inspector general's office;

 3      governor's office of employer relations, or also

 4      referred to as "GOER"; the Legislative Ethics

 5      Commission; and the office of the attorney general.

 6             Several have declined to attend in person;

 7      but, also, several have also submitted written

 8      testimony, which we will include when we have our

 9      report at the end.

10             As the chair of this committee, and as a

11      legislator that is deeply committed to reforming

12      government oversight and accountability, I would be

13      remiss not to share my disappointment, of course, in

14      the absence of those who are not here today.

15             And I hope that the -- in the future, we will

16      be able to come together, to learn, to work

17      together, and to be able to really take the task of

18      transforming our government, to make sure that the

19      systems that surround us are actually systems that

20      can withstand accountability and anticorruption

21      work, and really make sure that the state of

22      New York is no longer considered a place where

23      corruption, unfortunately, lives and thrives.

24             To transform this culture, I think that

25      having an increased amount of transparency in







                                                             7
 1      government is essential, and to be collaborative as

 2      well.

 3             So I just highlight those things because it

 4      is an important part of moving forward.

 5             And so let's hope, for the future, that we

 6      are able it to partner.

 7             Without meaningful transparency and

 8      accountability, New York State will never reach its

 9      highest potential.

10             And I think that New York State is one of the

11      greatest places on earth, and deserves the absolute

12      best.

13             And so with new leadership at the helm, we

14      are going to, hopefully, use this opportunity to

15      enact real change next year.

16             And I look forward very much to working with

17      everybody beyond not only today, but in this

18      upcoming legislative session.

19             And so with that, I will hand it to my

20      co-chair, if she would like to say a few words

21      before we begin with our first panel.

22             SENATOR KRUEGER:  Thank you very much.

23             I have to say, I think that Senator Biaggi

24      pretty much said it all.

25             I think the one thing I would add, well, when







                                                             8
 1      you talk about ethics in government, you sometimes

 2      default to the problem corruption.

 3             But I would also argue, just looking at the

 4      number of different agencies in the state of

 5      New York who might have a role here, you become

 6      aware of how there is great confusion out there as

 7      to, who is instructing whom, who does one report to

 8      if one has a problem.

 9             And, if you get conflicting information from

10      different entities, what do you do with that?

11             So I would also argue that it's critical, if

12      we want to accomplish the goals that Senator Biaggi

13      just laid out, that we also ensure that there is a

14      strong educational component of any entity that is

15      responsible for ethics in the state of New York,

16      because I fundamentally believe, after 20 years in

17      government, almost no one runs for elected office

18      with a goal of becoming corrupt.  Almost no one

19      takes a job in government because their goal is

20      corruption.

21             They slip and slide off the road over the

22      course of years.

23             They crossed lines because they didn't know

24      the lines existed.

25             They crossed lines because they felt forced







                                                             9
 1      into situations that they didn't know who to talk to

 2      to resolve the issue.

 3             So my goal, also, in improving the models we

 4      use in New York State, to assure the people of

 5      New York State that we have an ethical and fair

 6      government, is that we make sure everyone has access

 7      to the information they need before they ever get to

 8      that point where they're making a decision that may

 9      put them across legal lines or moral lines; because

10      I think it is so, so important that we make it

11      extremely clear to anyone who is taking jobs in

12      government, or who is doing business with

13      government, that we all know what the rules are and

14      that we're going to be held accountable to them.

15             So it's not just those in government.

16             I mean, JCOPE has an important role, that

17      I believe they fail, in evaluating and educating

18      lobbyists as well, who have a very unique role in

19      government, and are often part of the problems when

20      they blow up, but rarely are held to account.

21             So I look forward to our continuing efforts

22      through hearings and through legislative change.

23             Thank you, Senator Biaggi.

24             SENATOR BIAGGI:  Thank you, Senator Krueger.

25             Would Senators Borrello or Boyle like to say







                                                             10
 1      a few words?

 2             Okay.

 3             SENATOR BORRELLO:  Thank you.

 4             First of all, I would like to say thank you

 5      very much for calling this hearing, Chairman Biaggi.

 6             Thank you for being here; and also

 7      Chairman Krueger.

 8             I'm a member of the Finance Committee, and

 9      certainly enjoy serving on that committee.

10             I would say that, you know, we have a crisis

11      when it comes to ethics in New York State, and

12      corruption is, unfortunately, baked into the system.

13             The biggest problem with it is a lack of

14      transparency.

15             And, quite frankly, our former governor

16      certainly ran roughshod over the legislature and the

17      people of New York State with the way he controlled

18      JCOPE.

19             You know, there's no greater example of that

20      than the fact that they actually approved that book

21      deal, that we now know was a disaster and a lie; and

22      on top of that, he was rewarded handsomely for it.

23             So we need to take a good look at this

24      situation.

25             Where are we going to improve ethics, and







                                                             11
 1      how?

 2             How are we going to ensure the people of

 3      New York have confidence that their government

 4      serves them, and that it is an open, transparent

 5      system.

 6             We don't have that right now.

 7             Ethics is just only a part of the problem,

 8      but it's certainly something that we need to start

 9      with.

10             So I'm glad to be here and discuss this, and

11      I appreciate the conversation.

12             Thank you.

13             SENATOR BOYLE:  And thank you,

14      Senator Biaggi, for holding these hearings, and

15      Senator Krueger.

16             I was fortunate to take part in the Albany

17      hearings, and learned a lot.

18             And I hope to look forward to learning a lot

19      more from our panelists today.

20             I think one of the problems, and you all

21      touched on it, is the fact that, in Albany, it's

22      really not so much the malfeasance that is done;

23      but, who's doing it, whether they're going to be

24      held accountable by ethics.

25             So when we look to replace JCOPE, or whatever







                                                             12
 1      we're going to do, the next [indiscernible] -- I've

 2      been in the legislature 27 years, so I've seen

 3      several different iterations of this -- we're going

 4      to get it right this time with your leadership.

 5             And thank you so much.

 6             SENATOR BIAGGI:  Thank you both so much.

 7             And with that, we can begin with our first

 8      panel.

 9             We will be joined remotely by

10      Nelson Sheingold, who is counsel to the

11      New York State Comptroller; and, Terri Crowley,

12      executive deputy comptroller for operations.

13             And we're very grateful to have the office of

14      the state comptroller here with us here today.

15             Thank you both so much for joining us

16      remotely, and we look forward to hearing your

17      testimony.

18             NELSON SHEINGOLD:  Thank you very much,

19      Senator Biaggi, and thank you for inviting us; and

20      thank you, Senator Krueger, Senator Borrello,

21      Senator Boyle, and all of the distinguished

22      committee members.

23             I thank you on behalf of

24      Comptroller DiNapoli.

25             My name, as Senator Biaggi said, is







                                                             13
 1      Nelson Sheingold, and I have the privilege of

 2      serving as counsel to State Comptroller

 3      Tom DiNapoli.

 4             I'm joined today by Terri Crowley, our

 5      executive deputy comptroller, who heads our office

 6      of operations.

 7             New Yorkers have seen way too many scandals

 8      involving public officials in recent years.

 9             The activities of those who abuse their

10      office compel us to take all possible measures to

11      restore public confidence in our government.

12             This can only be accomplished through

13      enhanced transparency and accountability.

14             Under the state constitution, our state law,

15      the state comptroller's office is the independent

16      watchdog of taxpayer funds, and an integral

17      component in the fight against public corruption,

18      fraud, waste, and abuse.

19             Comptroller DiNapoli has been, and will

20      always continue to be, committed to maximizing the

21      authority and resources of this office to combat

22      corruption, and eliminate waste, fraud, and abuse of

23      public funds.

24             In the fight against public corruption, we

25      work with law enforcement at all levels of







                                                             14
 1      government, in all 62 counties of the state, with

 2      all of our U.S. attorneys' offices, the attorney

 3      general, the state police, the FBI, and numerous

 4      other federal, state, and local agencies, to

 5      aggressively root out public corruption and fraud.

 6             This work has, thus far, resulted in over

 7      250 arrests, and the ordered recovery of over

 8      $78 million since the inception of

 9      Comptroller DiNapoli's anticorruption initiative.

10             But fraud detection is simply not enough.

11             Through the hundreds of audits of state and

12      local governments and public authorities we conduct

13      every year, we proactively identify deficiencies in

14      internal control gaps, and make recommendations to

15      improve efficiency, and prevent fraud before it

16      occurs, and before there's any misexpenditure [sic]

17      of taxpayer funds.

18             The comptroller's duty to audit state

19      payments, and the authority to review and approve

20      state contracts before they take effect, are a core

21      function of the comptroller's office, and vital

22      checks on waste, fraud, abuse, and corruption.

23             For 2021, cumulatively, through October of

24      this year, the comptroller's office has already

25      approved over 14,000 contracts valued at over







                                                             15
 1      $163 billion, and has approved nearly 171 million

 2      payments worth more than 174 1/2 billion dollars.

 3             At the same time, this office has rejected

 4      over 1300 contracts and related transactions, valued

 5      at over $5.4 billion, and nearly 218,000 payments

 6      valued at nearly $262 million, primarily due to

 7      errors, improprieties, or lack of sufficient

 8      supporting documentation.

 9             Our independent oversight of state contracts

10      is an essential check and balance, and critical in

11      providing assurance that public funds are being

12      appropriately spent.

13             Unfortunately, over the last decade, through

14      the state budget and legislation, our

15      contract-approval authority has been chipped away

16      at.

17             Now, a common justification for voiding our

18      review rests on the supposed delay in the

19      procurement process.

20             This is simply unpersuasive.

21             Actually, on average, our review of contracts

22      takes less than a week.  And when it takes us

23      additional time to exam a proposed contract, and ask

24      appropriate question, it's for a very good reason;

25      namely, to fulfill our job, to ensure that public







                                                             16
 1      moneys are appropriately spent.

 2             We urge the legislature to eliminate any

 3      further circumventions of our approval authority,

 4      whether it be in the budget or through proposed

 5      legislative action, and to restore that authority

 6      that has been taken away over the last decade.

 7             On this note, Senator Reichlin-Melnick

 8      recently introduced a bill which would restore much

 9      of our contract approval authority, which is pending

10      before you.

11             Comptroller DiNapoli also believes that

12      transparency is critical, and we've taken action to

13      back that up.

14             The comptroller's "Open Book New York"

15      website contains information on over 190,000 state

16      contracts; the ability to search payments dating

17      back to 2012; detailed revenue, spending, debt, tax

18      limit, balance sheets, and property tax information

19      for our over 3100 local governments in New York,

20      dating back to '07.  It has financial information

21      for more than 500 state and local public

22      authorities, also stating back to '07; and other

23      related budgetary and financial information about

24      state agencies to educate the public.

25             More specifically, in October we launched a







                                                             17
 1      publicly accessible dashboard to track certain

 2      federal COVID funding, and state relief programs, so

 3      New Yorkers can monitor the spending of these funds

 4      in the state.  This includes funds for excluded

 5      workers, child-care services, emergency rental and

 6      homeowner assistance, and small-business recovery.

 7             Additionally, our fiscal-stress monitoring

 8      system provides an early warning to local government

 9      and their citizens regarding the financial state of

10      their local governments which they live in.

11             Our audit reports that I mentioned earlier

12      are all publicly posted on our website for citizens

13      to review and use in making informed decisions as

14      they participate in their government.

15             In closing:  Comptroller DiNapoli has been,

16      and remains, committed to using his office, and

17      partnering with the legislature and executive, to

18      promote accountability and transparency in

19      government at every level.

20             And I look forward, as does Ms. Crowley, to

21      answering any questions the panel may have.

22             Thank you.

23             SENATOR BIAGGI:  Thank you very much for your

24      testimony.

25             I will ask questions last.







                                                             18
 1             And so, if Chairwoman Krueger would like to

 2      begin, I'm happy to start with her, of course, and

 3      then we'll go back and forth with questioning.

 4             But thank you very much.

 5             NELSON SHEINGOLD:  Thank you.

 6             SENATOR KRUEGER:  Thank you both for

 7      attending, and giving us a chance to review your

 8      testimony and think of additional concerns.

 9             So you referenced the contracts that the

10      State of New York does, which are billions and

11      billions of dollars a year, and the important role

12      that the comptroller's office plays in both

13      reviewing and auditing.

14             Can you help me understand, because I think

15      lots of legislators don't necessarily, what role we

16      can and cannot play in this process?

17             Because it is my understanding that we are

18      not allowed to attempt to influence who gets what

19      contracts in the state of New York.

20             But it's also true that it's very common that

21      a business that might be in our district contacts us

22      and says, We're trying to do business with the State

23      of New York, and we wonder whether you can be

24      helpful?

25             So help me understand where being helpful







                                                             19
 1      stops, and crossing a line into attempting to

 2      influence the outcome of who gets a contract starts.

 3             NELSON SHEINGOLD:  Thank you,

 4      Senator Krueger.

 5             Well, as you're aware, the legislature is

 6      exempt from the procurement lobbying laws that would

 7      directly apply to the vendors, or potential vendors,

 8      or sometimes losing vendors, frankly, who have

 9      contracts before the State.

10             So that would not apply as it would to some

11      other people who reach out to us.

12             The key, from our perspective, is we do our

13      reviews independently.

14             As you know, our reviews, just like our

15      audits, are conducted by career civil servants who

16      apply objective standards, to make sure what's

17      before us comports with the law that applies to that

18      particular contract; whether it requires competitive

19      bidding, the process that was used to secure that,

20      and whether the prices are reasonable.

21             So we will not be, and are not, influenced as

22      to when it can cross the line, you know, crossing to

23      areas of legislative ethics; and then, at worst, as,

24      unfortunately, we have seen in some past scandals,

25      outright corruption.







                                                             20
 1             So, and there are obviously criminal laws and

 2      other laws that would limit that.

 3             But once again, from our perspective, when we

 4      look at a contract, and our career, very

 5      experienced, very good, frankly, civil servant to

 6      look at it, we're going to look at it objectively,

 7      and we're going to look at what comes in from the

 8      agency, and do our own review.

 9             SENATOR KRUEGER:  So I could call you and

10      say, "I really like this group, I hope they can get

11      a contract," that wouldn't be crossing the line?

12             NELSON SHEINGOLD:  Once again, everything

13      would be that specific, Senator.

14             Like I said, and maybe this is something that

15      warrants a review, but under the procurement

16      lobbying laws that would apply, the legislature is

17      not included.

18             So that would not be a per se violation like

19      it would, say, if some vendor or chamber of

20      commerce, or I can make up a million hypotheticals,

21      would, where we couldn't look at it, and we would

22      say, You have to go to the agency contact.

23             So that's, once again, the legal standard.

24                [Simultaneous talking.]

25             NELSON SHEINGOLD:  Yes, please go ahead.







                                                             21
 1             TERRI CROWLEY:  I can say, from an

 2      operational perspective, what we would say to anyone

 3      who calls, we simply say the status of a contract.

 4             We don't -- we make it clear that we are

 5      independent, whether it is a member, a lobbyist,

 6      another group.

 7             And what our main objective is, we can tell

 8      you the status of the contract, and that's pretty

 9      much the extent of it.

10             SENATOR KRUEGER:  Got it.

11             And so we know that a registered lobbyist can

12      talk to you about their client's application for a

13      contract; right?  That's true?

14             NELSON SHEINGOLD:  Correct.  You're right.

15             TERRI CROWLEY:  Yes.

16             NELSON SHEINGOLD:  Correct.

17             SENATOR KRUEGER:  And can a registered

18      lobbyist for a client contact a legislator and ask

19      them to get involved?  Is that a conflict of

20      anything?

21             NELSON SHEINGOLD:  Once again, I -- you know,

22      I'm going to not feign expertise in the lobbying

23      law.

24             But, from our perspective, obviously, if they

25      contacted us, that would be absolutely in a







                                                             22
 1      restricted period and we would not converse with

 2      them.

 3             The restrictions on conversations between

 4      lobbyists and the legislature, I would not fully

 5      opine on.

 6             SENATOR KRUEGER:  So I think there are a

 7      couple of holes in the law that we need to address.

 8             But let me ask the reverse question.

 9             Give me an example of a case of corruption in

10      contracting that the comptroller's office got

11      themselves involved in.

12             You know, what was the -- give me -- you

13      don't have to name the names, but just give me an

14      example of what actually happened, that made you

15      realize that there was a violation of law here that

16      you needed to insert yourself into in some way.

17             NELSON SHEINGOLD:  First, if I could just

18      spare a little bit, Senator Krueger, when we look at

19      contracts that come in, and I mentioned some

20      improprieties before, the primary thing we're

21      looking at, once again, does it comply with the law?

22      And to use a technical legal phrase, whether it

23      looks kosher coming in.  That's the primary, and we

24      will look at it.

25             And I can think of examples, and it's hard







                                                             23
 1      not to mention it, of ones that did not come here,

 2      which I can't believe we wouldn't have tracked and

 3      we wouldn't have flagged if they did.

 4             The ultimate example being the whole

 5      situation with the Buffalo Billion and

 6      Alain Kaloyeros, which, on its face, is incredibly,

 7      incredibly tailored when it comes in.

 8             So, if it did come in; and, unfortunately, it

 9      didn't under current law.

10             So it's very easy to pick, once again,

11      situations like that.

12             As I said before, we reject thousands of

13      contracts every year, based on different

14      improprieties, and others.

15             And, also, and I want to point out one other

16      thing, in addition to what we may or may not catch

17      coming in that may be fraudulent, the very fact that

18      our review is there serves as a deterrent because

19      they know it's coming here.

20             And, in fact, and I take this as a mark of

21      honor, we've had agencies tell us, and I've had

22      vendors mention that agencies have said, Oh, I can't

23      do that, or, Don't put in that clause, because the

24      comptroller's office will never, ever approve that.

25             As you know, we also serve, as we look at bid







                                                             24
 1      protests that come in, and we grant them, you know,

 2      several every year, where the agency is approved,

 3      the target-bid protest comes to us, and we'll say,

 4      No, that wasn't kosher.

 5             So I can think of many examples of that off

 6      the top of my head.

 7             But, unfortunately, a lot doesn't come to us

 8      anymore.

 9             SENATOR KRUEGER:  And it's great that you

10      referenced the Buffalo Billions example, with the,

11      sort of, I was going to say offshore contracting,

12      but it wasn't offshore, you know, creating entities

13      within a different state agency.

14             Does the comptroller's office have specific

15      language that you think we need to put into

16      legislation to prevent that from happening, and

17      prevent people from being able to skip the

18      comptroller's process?

19             NELSON SHEINGOLD:  Yeah, well, first of

20      all, I think what needs to happen is,

21      Senator Reichlin-Melnick's bill needs a good look

22      at, because, once again, that would restore us back

23      to where we were in 2011, where we had much, much,

24      much more robust review over SUNY contracts,

25      CUNY contracts, and OGS centralized contracts, which







                                                             25
 1      encompass billions of dollars and thousands of

 2      contracts every year.

 3             So that would be the perfect first step to

 4      start and restore what was lost.

 5             But then, going forward, it's -- we would say

 6      it's imperative to stop any further erosion,

 7      especially once it's restored.

 8             This has been an erosion over time, starting

 9      with the big chip-away in 2011 and 2012 that I just

10      mentioned.  But, in every year's budget, there seems

11      to be another part where we're not withstood and

12      avoided.

13             So just to make sure it doesn't get slipped

14      into the budget, that's not incorporating a

15      language, and allow us to review it, both as an

16      active review-and-oversight system; but, also, as a

17      very effective deterrent.

18             TERRI CROWLEY:  Yeah, and I would just like

19      to add one thing.

20             A lot of our authority rests with Section 112

21      of the state finance law.

22             And you will see, as Nelson said, in this

23      past budget alone, probably at least a dozen

24      examples, you know, there's an appropriation, not

25      withstanding Section 112 of the state finance law.







                                                             26
 1             So every time that happens, we're taken out

 2      of the review.

 3             So I -- to Nelson's point, I think what we

 4      would hope and recommend that you would -- you know,

 5      that the legislature would be very careful when

 6      inserting that language, because, again, it takes us

 7      out.

 8             We were taken out of billions of dollars in

 9      this past budget.  And it happens over and over and

10      over again.  So....

11             SENATOR KRUEGER:  That's excellent to keep

12      track of.

13             What about contracting through public

14      authorities; is your role different when the

15      contracts go through an authority?

16             NELSON SHEINGOLD:  Yes.  Under the public

17      authorities law our role is different.

18             For a contract to be called by this office,

19      it has to be over a million dollars.  It can either

20      involve a noncompetitive process or state money.

21             So, obviously, it's a much, much, much higher

22      threshold, and we have to call for it to review it.

23             Now, I will note there is a bill pending in

24      the Assembly, which would require public

25      [indiscernible] -- that's a program bill







                                                             27
 1      Comptroller DiNapoli -- that would require public

 2      authorities to promulgate guidelines, and internal

 3      procurement guidelines, that are consistent with the

 4      guidelines that apply to state agencies under

 5      Section 163 of the state finance law.  It would hem

 6      them closer because, right now, it's completely

 7      inconsistent.  They can come up with their own

 8      rules.  And they could come up by a new resolution

 9      with a -- a resolution to avoid competitive bidding.

10             So it is a higher standard than it would be

11      with state contracting, even before the 2011

12      chip-away.

13             SENATOR KRUEGER:  Great.

14             I don't want to monopolize, so I'm passing it

15      back to you, Senator Biaggi.

16             Thank you very much.

17             SENATOR BIAGGI:  Thank you, Senator Krueger.

18             Those were excellent questions.

19             I just want to knowledge that we've been

20      joined today by Ranking Member Senator Palumbo.

21             Welcome.  We're happy to have you.

22             And I would like it to just hand it over to

23      my colleagues; so, please.

24             SENATOR PALUMBO:  Thank you, Madam Chair.

25             And thank you today for coming.







                                                             28
 1             And this is obviously something that's of

 2      great significance to all of us.  I know we've been

 3      talking about this for years.

 4             So I'm just certainly pleased.

 5             I've read through the testimony.  And if

 6      I have any further questions, of course I'll jump

 7      in.

 8             But I do certainly appreciate Senator Biaggi

 9      and Senator Krueger, the two chairwomen, for moving

10      this ball forward, because this is something that

11      we've all been critically concerned about.

12             And we certainly appreciate your input.

13             So, thank you.

14             SENATOR BIAGGI:  Thank you.

15             And, yes, please, Senator Borrello has a few

16      questions.

17             SENATOR BORRELLO:  Thank you.

18             First of all, thank you both for appearing

19      today; appreciate it.

20             I will say that Comptroller DiNapoli

21      certainly has the utmost respect of myself and many

22      others I would say on both sides of the aisle, and

23      you've done a great job in that office.

24             I sit on -- I am the ranking member of the

25      Procurement and Contracts Committee, which







                                                             29
 1      Senator Reichlin-Melnick is the chair of, and I'm

 2      glad to hear there's legislation to try and restore

 3      your oversight of all these contracts.

 4             My concerns lie with the shockingly

 5      increasing number of contracts that have been

 6      awarded to companies outside of New York State.

 7      That seems to have ramped up in the last several

 8      years, particularly under our former governor.

 9             And my concerns are, a number of things.

10             First of all, I don't think New York State

11      taxpayer dollars should be going to companies out of

12      state.

13             Yes, it's a lot cheaper to go out of

14      New York State, but that's because, largely, it's

15      too expensive to do business in New York State.  And

16      I don't think our taxpayer dollars should be going

17      in that manner to save money in that way.

18             But my question to you is:

19             When it comes to oversight of those

20      companies, I have heard concerns that, quite

21      frankly, it's difficult to understand the different

22      state laws, and the lack of being able to fairly

23      assess those contracts for companies that don't

24      operate under New York State laws.  That's a

25      challenge.







                                                             30
 1             So could you speak to that, and the ability

 2      for you to be able to root out corruption, and also

 3      being a proper oversight?

 4             NELSON SHEINGOLD:  Thank you, and

 5      I appreciate your kind words about our office and

 6      Comptroller DiNapoli's work.

 7             Yes, you know, obviously, we cannot act to

 8      determine where contracts are let, and what vendors.

 9      That's limited by New York State law.  We can only

10      apply New York State law when we do our contract

11      review.

12             But to your question, when you have

13      out-of-state entities -- and, particularly, now I'm

14      putting on my hat of investigations I have been

15      conducting for the last, you know, in fact, 27 years

16      of my life -- it presents some logistical challenges

17      when you have allegations of particularly

18      corruption.

19             They're out-of-state, sometimes not

20      susceptible to administrative subpoena process,

21      witnesses are not, you know, to be brought around

22      the corner.

23             So in the corruption-investigation sense, it

24      absolutely could present some challenges.

25             You know, contract review, when we do our







                                                             31
 1      initial contract review, it's subject to authority.

 2      You know, that's more of a paper we're looking at,

 3      the documentation, we're asking documentation.  We

 4      could hold back our approval, when the legislature

 5      has given us that authority, before we get certain

 6      documentation.

 7             So we have leverage in that situation.

 8             But, definitely, especially when you have an

 9      allegation of corruption, it could absolutely

10      present some logistical and practical and legal

11      hurdles.

12             SENATOR PALUMBO:  Thank you.

13             Actually, I have a bill that did pass

14      procurement and contracts this past year, to,

15      essentially, give in-state contractors a last look,

16      so that they can match the lowest responsible bid of

17      an out-of-state contractor.

18             So in addition to that, I think being a

19      better use and more responsible use of taxpayer

20      money, in essence, would also give you a slightly

21      easier job in being able to review those contracts

22      and root out corruption.

23             Would you agree?

24             NELSON SHEINGOLD:  You know, once again,

25      especially in the corruption arena, like I said,







                                                             32
 1      there are definitely hurdles when it's out-of-state

 2      or out-of-country vendors.

 3             SENATOR PALUMBO:  Great.

 4             Well, and as far as -- thank you.

 5             And as far as the oversight that you are

 6      currently -- this bill that Senator Reichlin-Melnick

 7      has, how would that improve -- in your opinion, how

 8      would that improve your ability to, you know, expand

 9      your oversight?

10             NELSON SHEINGOLD:  Once again, it would

11      restore what's been taken away over the last decade.

12             So, for example, if you look at the state

13      procurement rules, before you even get --

14      competitive bidding process, first, you have to see

15      if there's a preferred source available; then you

16      look at the centralized contract; and then you get

17      to competitive bidding.

18             Well, once again, back in 2011, by statute,

19      our review of centralized contracts was taken away.

20             Now, we were able, through an MOU, to get

21      some of it back.  But once again, that's by a mere

22      MOU.

23             So you're talking the second step in the flow

24      chart that was statutorily removed from our

25      oversight authority.







                                                             33
 1             And then you see what was taken away in terms

 2      of SUNY and CUNY.  Like Ms. Crowley said, we're

 3      talking billions of dollars that flow through that

 4      don't come before us.

 5             So I think it would be a marked improvement

 6      in oversight and protection.

 7             And as I said in response to

 8      Senator Krueger's question, we also can't, you know,

 9      be -- forget about the deterrent effect, and the

10      check effect, it has on all state agencies and

11      vendors.

12             SENATOR PALUMBO:  Could you give me the

13      percentage of what contracts, under the changes that

14      were made in the last decade, what percentage of

15      dollars, overall, that you are not overseeing at the

16      moment because of the current situation?

17             NELSON SHEINGOLD:  I don't have that number

18      off the top of my head.

19             TERRI CROWLEY:  Well, I could tell that we

20      looked at -- went from 2011 to when the MOU took

21      effect, it was close to $3 billion of contracts that

22      were done without -- outside our review.

23             And just to underscore what Nelson said too,

24      an MOU, yes, it's better than having no authority,

25      but it's administrative, and it could be gone, you







                                                             34
 1      know, if someone decides they don't want it in

 2      effect anymore.

 3             So that's why we believe it's absolutely

 4      essential that our authority be restored

 5      statutorily.

 6             SENATOR PALUMBO:  All right.

 7             Thank you very much.

 8             NELSON SHEINGOLD:  Thank you.

 9             SENATOR BIAGGI:  Thank you.

10             And so now we will hear from Senator Boyle.

11             And, again, just as a reminder, I will be

12      asking questions last.

13             SENATOR BOYLE:  Thank you, Senator.

14             And thank you for appearing, and I share my

15      colleague's sentiments about Comptroller DiNapoli

16      being the gold standard in terms of ethics in state

17      government.

18             I've known Tom many, many years, and there's

19      never been a hint of any scandal whatsoever.  Truly

20      amazing.

21             Just to go back to Senator Krueger's remarks

22      about a legislator getting involved, I'll give you

23      an example.

24             Say a constituent company of mine writes in,

25      Hey, we're bidding on widgets for the New York State







                                                             35
 1      government.

 2             And we would typically write a letter, Please

 3      give, you know, the Smith Widget Company your utmost

 4      consideration in this.

 5             You know?

 6             Is it -- would there -- any be problem with

 7      that?

 8             Or -- I mean, I just -- I mean, obviously,

 9      there's going to be no underhanded stuff in the

10      legislator's office, I'm getting paid for it.

11             But would that be -- pass the smell test, in

12      your opinion, Counselor?

13             NELSON SHEINGOLD:  Once again, under the

14      procurement lobbying law, that's a legal

15      correspondence.  It wouldn't fall within the rubric

16      of the prohibitions of that statute.  But, you know,

17      once again, to emphasize, you know, what Terri said,

18      we are going to look at it objectively.

19             We have to -- and I think this is an

20      overarching theme when this committee and

21      New Yorkers look at ethics and ethics reform -- you,

22      me, both, actual lack of conflict of interest, and

23      actual independence, and the perception of such.

24             I mean, we are very, very, very cognizant of

25      that fact.







                                                             36
 1             So we will receive anything that comes to us

 2      legally.  We will put in the procurement record

 3      because we're above board.  And then we will do our

 4      robust, independent, and objective review of that

 5      contract, because the only way we restore public

 6      confidence is actual independence and the perception

 7      of independence.

 8             SENATOR BOYLE:  All right.  Thank you.

 9             And one further question.

10             So I believe in your remarks you said that

11      the review of a contract typically takes less than a

12      week by the comptroller's office.

13             And I remember, our former governor, when

14      they created the -- when they passed the 2011 laws,

15      the big thing was, Oh, the contracts go to the

16      comptroller's office, and months, years, later

17      they're still looking at it, and it slows everything

18      down.

19             So any way that you can work with the

20      committee and the legislature for language, to make

21      sure that that is not the case, and is not even the

22      perception of the case, that they're not -- things

23      are not being slowed down, so you can rightfully

24      review these contracts to -- for ethics concerns?

25             Okay?







                                                             37
 1             NELSON SHEINGOLD:  Yes, thank you.

 2             And we will gladly work with the legislature,

 3      to look at procurement reform.

 4             And once again, on average, statistically,

 5      over the last few years, a contract stays here, an

 6      average, including the ones that last longer,

 7      5.8 days.

 8             So I give a little fudge on it.  It's

 9      actually well less than a week.

10             And I want to again emphasize, ones that stay

11      here longer, not that they're necessarily corrupt or

12      infirmed, but there's a reason for it, because we're

13      going to ask the appropriate questions.

14             You know, oversight, and checks and balances,

15      are not built for speed; but quite the opposite.

16             But we will gladly work with the legislature,

17      to reach a balance, and make sure that we have

18      appropriate oversight of functioning.  Absolutely.

19             TERRI CROWLEY:  And I would just like to also

20      just quickly underscore too, those contracts that

21      are with us longer, keep in mind, some of our

22      contracts are hundreds of millions of dollars,

23      billions of dollars.

24             So, you know, it would be highly unlikely we

25      could review a billion-dollar contract in 5.8 days.







                                                             38
 1             But we are, you know, mostly under the time

 2      that we're given.

 3             So it's, just -- you know, when you're

 4      looking at 14,000 contracts, and thinking, you know,

 5      the average is 5.8 days, that's a pretty good

 6      standard, at least in our book.  So....

 7             SENATOR BOYLE:  Thank you.

 8             NELSON SHEINGOLD:  Thank you.

 9             SENATOR BIAGGI:  Thank you very much.

10             I would like to acknowledge that we have been

11      joined by my colleague, Senator Hoylman.

12             Thank you, and welcome.

13             Senator Hoylman, we are on the comptroller

14      panel right now.

15             And so, if I may --

16             And, of course, if you have questions,

17      Senator Hoylman, just let me know.

18             -- I wanted to just ask a series of questions

19      in different topics; so I just want to outline the

20      different areas:

21             The first one being, your referral authority,

22      a little bit about auditing.

23             And then two questions about

24      sexual harassment, workplace discrimination, and the

25      inspector general.







                                                             39
 1             And so I just want to begin with your

 2      referral authority, because it's something we heard

 3      I think a lot about last year.  And I think for a

 4      lot of New Yorkers, it was the first time maybe they

 5      had heard about that authority.

 6             And so, under Executive Law, Section 63.3 --

 7      right? -- the comptroller's office has the authority

 8      to make a referral to the attorney general to

 9      investigate potential indictable offenses in

10      violation of the law.

11             So could you please explain the circumstances

12      where the comptroller may make such a referral, and

13      the process that your office follows to determine if

14      the referral is actually deemed appropriate?

15             NELSON SHEINGOLD:  Absolutely, Senator.

16             So as you articulate, Section 63.3 provides

17      us with blanket authority to make a criminal

18      referral within -- with any subject matter that

19      falls within our general authority.

20             So, once again, if it's something that

21      doesn't fall within the comptroller's authority,

22      then we can't make a referral.

23             If it's something that falls within our

24      authority, and we deem it to be potentially

25      criminal, we could vest the attorney general's







                                                             40
 1      office with jurisdiction; and, in fact, we have, on

 2      many, many, many occasions.

 3             Of course, the latest and most notable being

 4      in regard to the book deal, which is in the paper.

 5             But that's just one of dozens and dozens of

 6      occasions where we have made referrals, at least

 7      over the -- over a decade I've been in the office.

 8             And in terms of when we make the referral and

 9      the process, it could come up in different ways.

10             So as I said earlier in my prepared remarks,

11      we've done, you know, our work, our anticorruption

12      initiative and the comptroller's strategic priority

13      to root out corruption, has resulted in over

14      250 public corruption and public-forward arrests.

15      We do those with local DAs, DAG, the U.S. Attorney.

16             So, generally, when we find a case of actual

17      fraud; or potential fraud, I should say, we'll

18      determine, you know, who is the most suitable law

19      enforcement agency to work with.  Sometimes it's the

20      AG.  Sometimes a local DA.  It's, very often,

21      case-specific.

22             Sometimes, in fact, very frequently, we'll

23      actually get a reach-out from a state or a local

24      authority, saying, Hey, we're hearing something

25      about this.  Can you look?







                                                             41
 1             You know, and as the watchdog of the public

 2      fisc, we'll go in, we'll look.  And when it

 3      obviously comes from a law enforcement authority,

 4      that's who we're going to work with, going forward.

 5             So it's very fact-specific and

 6      fact-dependent.

 7             But as you said, Senator Biaggi, we have the

 8      authority to refer to the attorney general's office,

 9      when appropriate, so long as it's something related

10      to our inherent powers.

11             SENATOR BIAGGI:  Okay.  That's very helpful.

12             And so -- so you're -- one of the things that

13      you mentioned was that, if it's not within your

14      authority, then you can't, of course, refer it.

15             So are there instances when an issue is not

16      within your referral authority, but then you can --

17      do you have the power to reach out to the entity or

18      the authority that actually does have the authority

19      to make that referral, for lack of better words, so

20      that -- to make sure that that issue is actually in

21      the right place?

22             NELSON SHEINGOLD:  Absolutely.  In fact, we

23      do that every single day.

24             So Comptroller DiNapoli has established a

25      hotline and Internet portal for the public to report







                                                             42
 1      fraud.

 2             We get over 4,000 fraud complaints, or

 3      potential fraud complaints, I guess I should say, or

 4      allegations, every year.

 5             If it's not within our authority, we don't

 6      just sit on it.  We will send it to who we believe

 7      to be the appropriate authority, or authorities, to

 8      look at it, to make sure that it ends up in

 9      somebody's hands so they can actually do something

10      with it.  And if there's any truth -- allegations,

11      they could be addressed.

12             SENATOR BIAGGI:  That's very helpful to know.

13             So going back to the referral authority with

14      regard to the attorney general, is this done through

15      an MOU, or is there a different set of powers that

16      you are -- that you have vested?

17             And in your referral authority in each,

18      whether it is a DA's office or a U.S. attorney's

19      office, is it necessary to have an MOU; or is it

20      simply just by the power that is delineated in the

21      statute?

22             NELSON SHEINGOLD:  The latter; it's by the

23      power delineated in the statute.

24             So for the attorney general, because, under

25      New York State law and the state constitution, the







                                                             43
 1      attorney general doesn't have original jurisdiction

 2      over the vast majority of crimes.

 3             They require, as you said, Senator Biaggi, to

 4      get a referral from us or another relative agency.

 5             So, in that, so, lateral, like the book deal

 6      letter that has been published in the press, as you

 7      know, it's a good example.  And they all pretty much

 8      look like that.

 9             Now, unlike the AG's office, DAs,

10      U.S. attorneys, and the other investigative bodies,

11      they don't require a formal referral.

12             So, frankly, a lot of times it's just a phone

13      call to deal with it, because they already have

14      jurisdiction to investigate; whereas, the AG needs

15      something in writing, under Court of Appeals

16      decision, from the comptroller, vesting them with

17      that authority under Section 63.3.

18             SENATOR BIAGGI:  Okay.  That is very helpful

19      to understand.

20             And so where it is -- where there's no formal

21      referral process, does the comptroller's office keep

22      a record of all of the outreach that it makes to

23      these various other agencies?

24             NELSON SHEINGOLD:  Well, we track -- we

25      obviously track cases that come in in complaints.







                                                             44
 1      Like I said, a lot are just a phone call from a DA's

 2      office.

 3             SENATOR BIAGGI:  Okay.

 4             NELSON SHEINGOLD:  So the results in the

 5      case, obviously, you know, we'll keep records.

 6             SENATOR BIAGGI:  Got it.

 7             NELSON SHEINGOLD:  There's different levels

 8      of formality, depending on the nature of the

 9      referral, the reach-out, and the like.

10             You know, and I should also point out,

11      Senator Biaggi, and I would be remiss if I didn't,

12      Comptroller DiNapoli has established a process, that

13      when we're doing the hundreds of audits I referred

14      to earlier, be it of a local government, a state

15      agency, operations, any part of this agency, if we

16      even get a hint of fraud, we'll take a look at it

17      and see if there's potential fraud there.

18             If there is, we'll tease it out, we'll see if

19      there's fraud there.  And if we do determine there's

20      fraud, we'll make an active reach-out to whatever

21      relevant agency is out there that's appropriate to

22      address the situation.

23             So we're both proactive and reactive when it

24      comes to fraud, given the vast gambit of this

25      office's power.







                                                             45
 1             SENATOR BIAGGI:  That's very good to hear.

 2             One final question under the "referral

 3      authority" category.

 4             Do you think that your office would benefit

 5      from greater or broader referral authority?

 6             Is that something you know, you've discussed

 7      internally, or even to the public?

 8             Is there something that the legislature can

 9      do to give the -- besides, of course,

10      Senator Reichlin-Melnick's bill, which I think is an

11      excellent bill -- but that's a separate issue for

12      contracting; this is more about your referral

13      authority -- is there something that we can do to

14      make sure that you are, basically, capturing all of

15      these issues within your net?

16             NELSON SHEINGOLD:  As you said,

17      Senator Biaggi, I think Senator Reichlin-Melnick's

18      bill, and I guess I should say, the preventing the

19      further erosion of our [indiscernible] approval

20      authority, goes a long way to making sure you

21      increase what's coming through here, so we can

22      actively look and make sure there's not fraud.

23             But in term of our improving our referral

24      authority, right now it is very robust and related

25      to our power.







                                                             46
 1             So, obviously, we would discuss it

 2      internally.  And if we have any ideas, we will

 3      circle back, absolutely, with the legislature and

 4      let you know.

 5             But we have ample authority to refer right

 6      now, and to work with, frankly, any other agency

 7      that's joining us in the commitment to fight fraud.

 8             SENATOR BIAGGI:  That is very good to hear.

 9             Thank you for that.

10             So, now, just moving on -- auditing category

11      of questioning:

12             And I really have to just also say that I am

13      very grateful to the comptroller's office, who

14      helped my district during the beginning of the

15      pandemic, deal with a very important, pressing issue

16      in the city of Mount Vernon, and did it really, not

17      only with excellence, but also swiftly.

18             And I believe it was one of the first times

19      that there was a virtual component to doing audits,

20      and it was still done on time, and it was still done

21      in a way that was comprehensive.  And it was very

22      meaningful to ensure that the city of Mount Vernon

23      could actually function, because it wasn't,

24      unfortunately.  And that was, obviously, a very big

25      problem.







                                                             47
 1             And so, just, thank you very much for that.

 2             And so I think, under that category, can you

 3      just explain a little bit how your office approaches

 4      your auditing responsibilities, and how you

 5      prioritize audits that come in?

 6             Because I am sure that you receive a lot of

 7      them, and it would be helpful to understand how

 8      you're triaging them.

 9             NELSON SHEINGOLD:  Absolutely, Senator.

10             So we employ, generally, a risk-based

11      approach.

12             We employ that throughout the gambit of our

13      audit authority, be it on payment audits --

14      [indiscernible] contract comes under our approval

15      authority -- payment audits, local government

16      audits, or state audits, because you've got to

17      address where the problems are first.

18             So if we see a potential risk, which could

19      come from citizen complaints; it could come from our

20      fiscal monitoring system, that says, Look, there's a

21      real problem, and it's been out in the municipality.

22             It can come from the citizens coming to us.

23             It can come from the legislature reaching out

24      to us, and said, Hey, you've got to look here.

25             And, obviously, so we're going to employ that







                                                             48
 1      risk-based methodology to determine where our assets

 2      are most needed to remediate a problem, and find out

 3      what's going on, and answer these questions.

 4             Of course, in addition to that, on the local

 5      level, we try to make sure that municipalities don't

 6      escape audits for a long time, because, even if

 7      there's not smoke, it's always good to go in,

 8      because, like I said before, we're trying to shore

 9      up things to prevent or to minimize waste, fraud,

10      and abuse.

11             So it's more than, like I said, fraud; it's

12      waste also.  And, you know, I try not to lose sight

13      of that.

14             So it's a risk-based approach.

15             It's a universal approach, as we go through

16      every year and categorize what we do.

17             And that's how we try to direct our

18      resources.

19             TERRI CROWLEY:  And I would just also like to

20      add, from an operational perspective, which are the

21      divisions that I oversee, we are auditing every

22      single day.  We are processing, you know, thousands

23      and thousands of payments.

24             And as Nelson said, we have put in, and

25      proudly to say, some pretty advanced data analytics







                                                             49
 1      and risk-based procedures.  But it's -- you know,

 2      there's multiple levels of audits.

 3             But just to, you know, underscore, every

 4      single day we are auditing, and, you know,

 5      determining, you know, are payments legitimate? are

 6      the people that are getting them are those that are

 7      supposed to?

 8             So it's -- it's here, it's here, it's -- you

 9      know.  And then the bigger ones that we do

10      programmatically.

11             SENATOR BIAGGI:  That makes sense.

12             And so let's say, for example, in the audit

13      there is corrective action that is suggested, and

14      you give that to the town, municipality, whatever

15      entity it is, and it's not followed.

16             Is there anything that your office can do as

17      a result of the audit not -- the audit

18      recommendations not being followed?

19             Can you go back and audit again?

20             Can you, again, refer it to any other entity

21      or agency?

22             How does that work?

23             NELSON SHEINGOLD:  So, in general, with our

24      programmatic audits, our performance audits in

25      localities and state agencies, we have very little,







                                                             50
 1      if any, coercive authority to make them adhere to a

 2      corrective-action plan.

 3             What we do is, we can make recommendation,

 4      and also very important, as I said earlier, we

 5      publicize it; it's on our website.  We'll put -- we

 6      put out our audit, it's available to the general

 7      public.  We put out our recommendations.

 8             If the agency or municipality replies, we

 9      don't hide that.  We attach it too, and then we'll

10      put our response to that.

11             We absolutely do follow up audits, and we

12      post those online too.  And we'll put out there,

13      what are they following, what have they

14      administratively fixed, and the like.

15             So a lot of it is by, frankly, sunlight.

16             We get it out there, we tell the public, and

17      we urge; and, hopefully, we facilitate citizens

18      getting involved.

19             And we've had many instances where you see in

20      the press, where a citizen said, Hey, the

21      comptroller pointed this out.  What are you doing?

22             So it's where we can make -- in those case,

23      we can make recommendations, and -- for improvement,

24      and, hopefully, educate, and arm and fuel, the

25      public to take action.







                                                             51
 1             SENATOR BIAGGI:  That makes sense.

 2             So then it -- would it fall within the

 3      governor's purview to require compliance?

 4             Do you know who the proper power is?

 5             Because, in the instance of Mount Vernon,

 6      that was just one example.

 7             In order to address a comptroller, or others,

 8      who are perhaps not doing the job that they've been

 9      elected to do, which is different, of course, than

10      appointed, it makes the accountability different,

11      the executive was the only person that could,

12      essentially, if necessary, remove the comptroller

13      from office.

14             And so is it only the governor, and we just

15      have to wait and see if the governor will do

16      something like that?

17             NELSON SHEINGOLD:  You know, it depends on

18      what the nature of the audit is.

19             So if it's a state agency under the

20      executive's control, obviously, the governor has

21      authority to take action.

22             In most cases, putting Mount Vernon aside for

23      a second, the governor doesn't have authority to do

24      anything to localities, and it falls to the local

25      boards and the local governing structure to take







                                                             52
 1      appropriate action to, you know, remediate the

 2      issues that we pointed out.

 3             So it -- really, you have to look at who --

 4      you know, once again, who runs the municipality, who

 5      runs the state agency.

 6             Obviously, we have constitutionally-protected

 7      home rule in New York.  So we vest our

 8      municipalities with independent authorities in terms

 9      of governance, in most instances.

10             SENATOR BIAGGI:  Okay.  That's very helpful.

11             And just one final question in this category,

12      and then we'll move on to the last one.  I know my

13      time is kind of ticking down here.

14             In terms of whether it's feedback or guidance

15      or brute force --

16             And I use that last term very intentionally,

17      because I really have in mind the former

18      administration who sometimes used entities of

19      government as retaliatory tools.

20             Do -- is the comptroller's office receiving

21      feedback from the governor's office or from the

22      executive branch regularly about who to do audits

23      on?

24             Obviously, you mentioned that there's a broad

25      range of people who are coming to you, there's a







                                                             53
 1      hotline.

 2             So, obviously, it's -- not that it's narrowed

 3      and only a few exclusive people can do this.

 4             But I'm just curious about this one aspect,

 5      and I specifically am, because the comptroller's

 6      office is in a very unique position, I think, than

 7      almost any other office.

 8             You have a power that is, in some ways, so

 9      removed from the governor's branch of -- of just the

10      chamber and the agencies, that it allows you to

11      actually do your job, as opposed to other agencies

12      or entities, like a JCOPE, which is obviously very

13      different.

14             And so I'm just wondering how you go about

15      that, or how you would go about that, or if you've

16      had experience, where a governor or a member of a

17      governor's team has said, "Well, we need you to do

18      this because," and the reason is very much not the

19      reason why you would do an audit; and what you would

20      do in that kind of situation, if that were to come

21      across your desk.

22             NELSON SHEINGOLD:  Well, you know, once

23      again, it's hard to answer in a hypothetical.

24             I will tell you, as you pointed out, one of

25      the virtues, or the main virtue, of the structure of







                                                             54
 1      the comptroller's office in New York is that

 2      Comptroller DiNapoli is an independently elected

 3      constitutional officer, which is much -- as you

 4      said, Senator Biaggi, is much different than many

 5      other states and many other agencies.

 6             So we don't have to follow the governor's

 7      direction, or anybody's direction, frankly, except

 8      for the taxpayers.

 9             So we will absolutely interact with state

10      agencies.

11             We do not take a combative approach, that is

12      not Comptroller DiNapoli's style, because, frankly,

13      that's not good government.

14             We will work with agencies, and Terri can

15      attest to this.  If there's something that needs to

16      be done in the public interest, be it on contracts,

17      we will work, how do we do this legally? who do we

18      do this efficiently? and the like.

19             We won't be bullied, and we haven't been

20      bullied.  We won't be directed.

21             We'll do our job under the constitution,

22      independently, where we need to go.

23             But, once again, good government is

24      collaboration.

25             As Senator Krueger said before, there are







                                                             55
 1      many agencies looking at this problem.

 2             We shouldn't be antagonistic to each other.

 3             When there's a problem and it's of public

 4      interest, we can work together, using our authority,

 5      to try and fix it.

 6             SENATOR BIAGGI:  I agree.

 7             TERRI CROWLEY:  And, Senator, I think too,

 8      just, it's almost the opposite the way it works.

 9             I think every agency understands, and

10      expects, we are going to audit you.

11             If you're making a payment, we are going to

12      audit you, because that's what we -- that's one of

13      our main focuses.

14             But to Nelson's point, and to

15      Senator Krueger's point, even with regard to

16      contract oversight, much to, you know, what some

17      people would argue, our goal is to get to "yes."

18             We want to -- we work with agencies to --

19      because we understand that the contracts that

20      they're trying to execute, for the most part, you

21      know, and there have been some exceptions, is to

22      provide essential goods and services.

23             So we want to get to "yes," but we want to

24      get to "yes" in a legal, ethical, and correct way.

25             So -- but, you know, again, to the thing with







                                                             56
 1      the agencies, I -- agencies expect, we are going to

 2      audit them, every single day.

 3             SENATOR BIAGGI:  That is good to hear.

 4             Thank you for that.

 5             I'm going to go to the second-to-last

 6      question because the last question is a little bit

 7      longer, and my time is ticking down here.

 8             So in terms of the category of sexual

 9      harassment, workplace discrimination:

10             Does the comptroller's office have to approve

11      any settlements that are made by state entities or

12      by legal services contracts, for example, in a

13      sexual harassment case, or settlement?

14             And, if so, how does your office review those

15      settlements or contracts?

16             NELSON SHEINGOLD:  Unlike the city

17      comptroller's office, which has to approve

18      settlements under state law, the state comptroller's

19      office does not approve a legal settlement in a

20      lawsuit.

21             That's within the purview of the attorney

22      general's office, which, obviously, New York is also

23      a separate constitutional actor.

24             So we will process the payment, and do what

25      needs to mechanically be done.







                                                             57
 1             But the actual authority, under New York

 2      State law, to enter into a settlement in the course

 3      of a lawsuit, be it in the court of claims, or 1983

 4      action alike, is vested directly in the attorney

 5      general's office.

 6             SENATOR BIAGGI:  So is that a unique function

 7      of New York State?

 8             Do other states do it like that?

 9             Do you know?

10             Or is that just something that has originated

11      through law, and that's just the way it's been, and

12      it might be better to be under your purview?

13             The reason I say that is really because,

14      sometimes it becomes -- because things are spread

15      out, it becomes confusing, even to someone like

16      myself who is paying attention and really in the

17      weeds on the details.

18             And so I'm just curious if that's the best

19      place for it, and if other states do it like that.

20             NELSON SHEINGOLD:  Yeah, I'm not -- I'm not

21      familiar with the practice across the country, what

22      other states do at this.  I'm only really familiar

23      with the way of New York.

24             SENATOR BIAGGI:  Okay.

25             NELSON SHEINGOLD:  Does it?  So I can't,







                                                             58
 1      unfortunately, provide you with information on that.

 2             In New York, as I said before, we do have an

 3      independent attorney general as the chief legal

 4      officer of the state.

 5             So I think there's good reason where the

 6      chief legal officer of the state would sign off on a

 7      legal -- a legal settlement.

 8             But --

 9             SENATOR BIAGGI:  That makes sense.

10             NELSON SHEINGOLD:  -- it's the only structure

11      that I've been familiar with.

12             SENATOR BIAGGI:  No problem.  I will have to

13      follow up myself on that one.

14             Okay.  And, then, just the final question is

15      with regard to the inspector general.

16             So in the previous administration there were

17      a lot of different concerns that were raised about

18      the independence and the transparency of the office

19      of the inspector general.

20             And in New York, the inspector general

21      reports directly to the secretary to the governor.

22             On the federal level, agency inspectors

23      generals are required to report to both, Congress,

24      as well as to the head of their agency.

25             And so I have introduced legislation that is







                                                             59
 1      very similar to the federal model, requiring the

 2      inspector general to report both to the legislature

 3      and to the secretary to the governor.

 4             But it has also been proposed that the

 5      inspector general could report to a third party; the

 6      third party being the office of the state

 7      comptroller.

 8             And so this might be a new idea for you, and

 9      you might need to take some time to think about it,

10      and I definitely give you the opportunity to do

11      that.

12             But, if you have any thoughts about that,

13      today, or later, I would really appreciate

14      discussing that with you, because one of the ways in

15      which our former ethics complaints and violations of

16      contracts and behaviors really fell through the

17      cracks was because of the one-track reporting; from

18      the agencies to the inspector general, and then the

19      inspector general to the secretary to the governor;

20      and whether or not the secretary to the governor

21      wanted to allow that complaint to proceed.

22             There was really nobody else that could have

23      any say in that process, which is highly

24      problematic.

25             So if you have any thoughts now, I would love







                                                             60
 1      to hear that.  If not, I would love to also talk to

 2      you about this another time.

 3             NELSON SHEINGOLD:  Yes, and I would have to

 4      take a look at that proposal, and we would have to

 5      get back to you.

 6             You know, I will make some thoughts, because

 7      I can't help myself.  But, I don't know.

 8             I'm actually -- I've been in the

 9      comptroller's office 11 years now.

10             Prior to that, I served as chief counsel for

11      the state inspector general, under the most

12      independent inspector general, as far as I'm

13      concerned, the state has ever seen, Joe Fish.

14             And one insight I got from that experience,

15      that I'll just throw out there, is you need two

16      components for effective oversight, be it the IG, or

17      anyone.

18             You need a system that works, of course, and

19      that is not so inherently flawed that even good

20      people can't make it work.  But just as important,

21      you need people who want to be independent, because

22      you can have a somewhat flawed system, and a good

23      person -- and by "a good person," somebody trying to

24      do the public good, who wants to be independent --

25      can make some good out of it.







                                                             61
 1             You can have the greatest system on earth.

 2      And if you have somebody who doesn't want to be

 3      independent, it's just empty words on a piece of

 4      paper.

 5             So in terms of, anybody, you need a system

 6      that enhances, facilitates, independence; and then

 7      you need people who want to be independent running

 8      that entity and doing the work.

 9             SENATOR BIAGGI:  I agree.

10             Thank you very much.

11             And, Senator Hoylman, if you have any -- do

12      you have any questions?

13             SENATOR HOYLMAN:  Yes.

14             SENATOR BIAGGI:  Oh, great.

15             SENATOR HOYLMAN:  Sure.  Why not?

16             SENATOR BIAGGI:  So I will hand it over to

17      Senator Hoylman.

18             SENATOR HOYLMAN:  Good morning.

19             I don't know if you can hear me?

20             Yes.

21             Good morning.

22             I just -- you know, the news of the morning

23      regarding the current situation at SUNY, and the

24      resignation proffered by the chancellor,

25      Jim Malatras, raises the issue of the blurring of







                                                             62
 1      the lines of supposed independent state agencies.

 2             In this situation, by most accounts, we had a

 3      chancellor, and I guess previously, a president, and

 4      I think at one point he was president of the

 5      Rockefeller Institute, another SUNY institution, who

 6      is working, in effect, as an arm of the governor's

 7      policy team, both political and policy, I would

 8      argue.

 9             What is the concern there, or is there one?

10             I mean, I believe that SUNY needs to be a

11      resource for policymakers.

12             But in this case, it seemed to have gone

13      overboard, where the -- his office seemed to be a

14      wholly-owned subsidiary of the executive.

15             And I think we saw that play out in the

16      attorney general's report.

17             But those of us who have witnessed the

18      collaboration between the SUNY chancellor, and in

19      his previous roles with the governor, particularly

20      when it came to statewide policymaking, always

21      seemed unusual at the time.

22             Should we be building a wall between SUNY and

23      the governor's office?

24             NELSON SHEINGOLD:  You know, it's obviously a

25      very general question, and a very important







                                                             63
 1      question.

 2             And Comptroller DiNapoli actually was

 3      interviewed yesterday by Alan Chartock, and talked a

 4      little bit about this.  So if you haven't heard it,

 5      you know, I would -- I think it's a good place to go

 6      to get the comptroller's thoughts on this.

 7             But it's always been a question, at least in

 8      the years that I've been in state government, about

 9      how independent all of these boards -- not just

10      SUNY, all the authority boards and the like --

11      should be; and how do you guarantee independence

12      when the appointing authority, you know, once again,

13      is dominated by one branch?

14             Like, once again, one example I would give,

15      moving away from SUNY a second, is, if you look at

16      our ethics bodies in this state, where, you know, my

17      27 years in government, I'm on my third one already.

18             In the latest iteration, it took away the

19      comptroller and the AG's ability to have a

20      nomination to that body, just to spread out, and to

21      disburse who these people are appointed by, and

22      maybe help a little with the control.

23             So I think that this is an issue that needs

24      to be looked at, probably for each individual

25      authority, its mission, and the like.







                                                             64
 1             But, once again, it also -- as I just said in

 2      relation -- last question, it also, frankly, comes

 3      back to people; it comes people -- it comes back to

 4      people in the executive, it comes back to people who

 5      are appointed to these various bodies.

 6             SENATOR HOYLMAN:  So that -- so the sheer

 7      number of gubernatorial-controlled appointees can

 8      make that difference on things like the board of

 9      trustees of SUNY, and other so-called "independent"

10      authorities and agencies?

11             NELSON SHEINGOLD:  You know, I think that's

12      clearly a concern, at least as a matter of

13      perception, at a minimum.  And I think it's

14      something, as the legislature has, worth further

15      examination.

16             SENATOR HOYLMAN:  Thank you.

17             NELSON SHEINGOLD:  Thank you.

18             SENATOR BIAGGI:  Thank you, Senator Hoylman.

19             Are there any further questions?

20             No?

21             Okay.

22             SENATOR PALUMBO:  Just a couple.

23             SENATOR BIAGGI:  Yes, okay.

24             Senator Palumbo, please.

25             SENATOR PALUMBO:  I just -- I just wanted to







                                                             65
 1      just make a general comment, that, you know -- and

 2      I do appreciate you folks coming, and I do

 3      appreciate the fact that you do work with

 4      municipalities.

 5             There was an audit in my district on

 6      Fishers Island, which actually is, you know, almost

 7      England.  It's about two miles off the coast of

 8      Connecticut and 11 miles from New York.

 9             But that's, basically -- and it's a small

10      municipality that had some real hiccups, because it

11      was, kind of -- only about 300 full-time residents.

12             And the comptroller worked with them, because

13      there were some real errors that were made.  And it

14      wasn't with a heavy hand that he came in to really

15      try and to hurt someone.

16             You said, Look, folks.  This is how you

17      really do this, and you made some huge mistakes

18      here.

19             And they were very receptive, of course.

20             And I just wanted to say that I do appreciate

21      that.

22             And the comments that you were making

23      regarding your audit authority are absolutely true,

24      and you do great work, and as does

25      Comptroller DiNapoli, as I think we all







                                                             66
 1      collectively have said at least once.

 2             You know, he certainly is a non-partisan, and

 3      very, very -- has a -- is a man of high integrity.

 4             So we do appreciate the work that you do.

 5             But that's all, just a quick comment.

 6             But, thank you.

 7             NELSON SHEINGOLD:  Thank you very much.

 8             SENATOR BIAGGI:  Thank you, Senator Palumbo.

 9             So before we conclude, I just want to say,

10      thank you again for being here today to answer our

11      questions.

12             I certainly learned a great deal about what

13      we can do.  And, also, I hope that the public also

14      learned about what you do on a daily basis.

15             And I want to just commend you as being the

16      only government entity that is here today; but we

17      look forward to that number growing with your

18      influence, and, hopefully, your experience here

19      today.

20             So thank you very much for joining us.

21             NELSON SHEINGOLD:  And thank you very much

22      for inviting us.

23             TERRI CROWLEY:  Yeah, thanks for the

24      opportunity.

25             SENATOR BIAGGI:  Thank you.







                                                             67
 1             Very good.

 2             All right.  Our next panel will actually be

 3      several of our good-government groups, and so we're

 4      going to jump to Panel 3 before we jump to Panel 2.

 5             And so we are going to hear from

 6      Blair Horner, Ben Weinberg, and Rachael Fauss.

 7             So please come up, and get ready to give your

 8      testimony.

 9             RACHAEL FAUSS:  Good morning.

10             My colleagues have been very kind to say

11      I should go first.

12             Can you hear me okay?

13             Well, my testimony should no longer say

14      "good afternoon" because it's actually the morning.

15             So, good morning, Senator Biaggi, and other

16      members of the Senate Ethics and Internal Governance

17      Committee.

18             My name is Rachael Fauss, and I'm the senior

19      research analyst for Reinvent Albany.  We advocate

20      for open and accountable New York State government.

21             And thank you for holding this important,

22      timely hearing, and we appreciate very much that

23      you're continuing the conversation from August, and

24      taking a comprehensive look at our ethics oversight,

25      by inviting other branches of government to testify,







                                                             68
 1      like the state comptroller.

 2             And I just have to say, having --ed to the

 3      testimony of the comptroller, I think it's so

 4      important, and I think -- I can't remember hearing

 5      where the comptroller's office ever talked about

 6      their oversight powers, especially around ethics.

 7      So I think this is new ground, and it was very

 8      interesting and important.

 9             So, thank you.

10             First, we'd like to reiterate our point from

11      the August testimony, that New York State has a

12      serious and ongoing corruption problem.  And the

13      Joint Commission On Public Ethics is worse than

14      useless and must be replaced.

15             But, obviously, this is not the entire

16      subject of today's hearing, so we're going to focus

17      on some of the other agencies, like the AG and

18      comptroller.

19             Some of the recommendations we have discussed

20      already, but I'll highlight some of the things that

21      Reinvent Albany supports.

22             We think the Senate should consider amending

23      Section 3 of the Executive Law -- this is on the

24      referrals -- in particular, to remove the

25      requirement that the AG -- to the governor after the







                                                             69
 1      governor makes referral, asking the AG to

 2      investigate the executive chamber.

 3             The law has a weekly report that the AGs

 4      must make.

 5             The governor -- former Governor Cuomo waived

 6      this for the referral that was made -- AG, but the

 7      law requires it.

 8             So I think that's something you should take a

 9      look at.

10             And as discussed, we think that you should

11      examine broadening the comptroller's referral

12      authority.

13             The Senate should also seek more information

14      about the use and limitations of the standing

15      agreement between the AG and the comptroller to

16      criminally prosecute corruption.

17             And some of the discussion today I think was

18      very interesting, and so you've begun that already.

19             The AG's office should prioritize and be

20      provided additional budgetary resources, if

21      necessary, to improve internal and external

22      databases, including the New York Open Government

23      website, and the Charities Bureau Registry.

24             These databases are important for the public,

25      legislature, journalists, to connect the dots on the







                                                             70
 1      flow of money in state government.

 2             The legislature should conduct an oversight

 3      hearing on the AG Charities Bureau, to determine

 4      whether it has adequate funding and technology, as

 5      discussed previously.

 6             I think that nonprofits constitute 18 percent

 7      of the state's workforce.  And there's a few, in

 8      particular, that we think the AG is well equipped to

 9      oversee, like the SUNY Research Foundation and the

10      many SUNY-affiliated charities that own public

11      property.  And we view these dozens of

12      state-chartered entities as having among the highest

13      corruption risk of any part of state government; in

14      particular, as we saw with the Buffalo Billions

15      scandal.

16             And, lastly, we think the Senate should hold

17      a hearing, assessing the role of the AG's Public

18      Integrity Bureau.

19             So at our last count, it had only a dozen

20      attorneys fighting corruption across the array of

21      state and local governments.

22             We understand you invited the AG to testify,

23      and they did not come.  But, you know, these are

24      some questions, hopefully, that you can have them

25      answer in some form.







                                                             71
 1             Regarding the comptroller, we support the

 2      preaudit authority of the comptroller being restored

 3      in law for state contracts.

 4             Obviously, we support the Reichlin-Melnick

 5      bill that was referenced by the comptroller's

 6      office.

 7             And just would draw your attention, also, to

 8      the Procurement Integrity Act of 2018.

 9             This was I think a program, though, of the

10      comptroller's.  It's something that I think you

11      could look at for potential language.

12             And I just notice -- just note that, in

13      addition to the 2011 actions that took place, and

14      then the erosion of the powers through the budget

15      for specific appropriations, executive orders also

16      have very frequently removed the comptroller's

17      authority under Sections 112 and 163 of the state

18      finance law.

19             And, you know, I know the Senate took some

20      action on executive orders earlier this year, but

21      it's something I think you should look at a little

22      bit more in terms of your powers to potentially

23      rescind ones that may be an overreach.

24             The comptroller should also be given

25      oversight of more public authority contracts, as was







                                                             72
 1      discussed.

 2             And we think that it's important to look at

 3      the OSC's potential oversight of use of forfeiture

 4      funds by local law enforcement agencies.  This is

 5      another area of potential corruption risk.

 6             And look into national best practices around

 7      transparency of settlements that are approved by

 8      state comptrollers, including for sexual harassment

 9      cases.

10             On the IG, we support considering additional

11      qualifications for the position of inspector

12      general, to create more independence, such as bars

13      on current government officials, lobbyists, vendors,

14      et cetera, from serving as IG, and believe the

15      legislature should consider requiring Senate

16      confirmation of this position.

17             And I know you mentioned your bill,

18      Senator Biaggi.  Haven't had a chance to read it

19      just yet, but I look forward to reviewing it.

20             On the Authorities Budget Office, this is

21      another area where they are a small agency that

22      oversee more than 600 public authorities, and do

23      work on ethics policies and conflicts of interest.

24             Right now they have a skeleton crew of

25      only twelve, and we support budget -- raising their







                                                             73
 1      budget to $5 million.

 2             And the last recommendation I have is, the

 3      legislature should look into creating a

 4      doing-business database.

 5             Ideally, this would be linked to campaign

 6      finance reform as well, for limitations on

 7      contributions from vendors.  But this is something

 8      that you could even consider doing outside of the

 9      realm of campaign finance, just as a way to help

10      you, again, connect the dots and follow the trail

11      of money through state government.

12             Thank you for your time.

13             I appreciate the hearing.

14             BLAIR HORNER:  Good morning.  My name is

15      Blair Horner.  I'm executive director of NYPIRG.

16             Thank you, Senators Biaggi, Krueger, Hoylman,

17      Palumbo, Borrello, Boyle, for all being here this

18      morning, and wearing a mask, to talk to us.

19             The ongoing fallout from the previous

20      administration is added -- mounting pile of evidence

21      that New York's ethics enforcement is in crisis.

22             The State's failure to establish and maintain

23      clear ethical guardrails and independent oversight

24      has contributed to the long history of scandals and

25      eroded the public trust in state government.







                                                             74
 1             The most recent disclosures by the

 2      attorney general of sworn depositions of the former

 3      governor and his top aides revealed shockingly

 4      unprofessional behaviors by top-ranking state public

 5      officials.

 6             That has to stop.

 7             NYPIRG strongly believes that the

 8      Joint Commission On Public Ethics and the

 9      Legislative Ethics Commission should be replaced

10      with an independent ethics enforcement agency that

11      would monitor and enforce ethics for the executive

12      and legislative branches.

13             The flaws recently revealed were mirrored by

14      predecessor agencies; namely, they relied on

15      commissions in which the members were directly

16      appointed by the political leadership of the state.

17             That obvious and inherent conflict of

18      interest undermined the agencies and fueled public

19      cynicism, and they didn't work.

20             The fundamental problem is that JCOPE's basic

21      commission structure is flawed.

22             The fact that the members are directly

23      appointed by the state's elected leaders severely

24      undermines its independence and accountability.

25             Regarding the Legislative Ethics Commission,







                                                             75
 1      including legislators on the panel destroys its

 2      independence.

 3             Having the regulator sit on a commission that

 4      regulates legislative and -- executive ethics is an

 5      obvious flaw.

 6             How best to reform?

 7             Well, one model is New York State's

 8      Commission on Judicial Conduct.

 9             The commission is established under the state

10      constitution, which helps limit political pressures

11      on decision-making.

12             Under this model, and this legislation

13      introduced by Senator Krueger, most of the

14      appointments to the new ethics commission would come

15      from the courts, thus reducing -- thus, giving it

16      sufficient independence.

17             But a constitutional amendment takes time.

18             We recommend that you consider legislation

19      that, while relying on bipartisanship, uses

20      randomness in the appointment process.

21             You can read it in our testimony; I go into

22      more detail.

23             The recommendation proposes that you replace

24      the appointment processes for both JCOPE and the

25      Legislative Ethics Commission.







                                                             76
 1             We use the selection process from the

 2      California Redistricting Commission as inspiration.

 3             By the way, we also agree with OSC having its

 4      powers restored and enhanced.

 5             There is a reason why the comptroller is a

 6      separately elected official, and that's their job.

 7      And when you erode their authority, it leads to, at

 8      least indirectly, corruption.

 9             We also urge that you establish a code of

10      conduct that makes clear that government officials

11      are the servants of the public and must behave in a

12      professional manner.

13             In our testimony, we cite the European

14      Council's language as an example.

15             And as you know, since the IG is chosen by,

16      and effectively reports to the governor, and

17      according to the former top lawyer -- former

18      governor, the person has a conflict of interest in

19      terms of investigating the governor's office.

20             Of course, that's just her opinion.

21             The current IG views her role differently.

22      And as you heard from Nelson earlier, Joe Fish

23      viewed his job differently as well.

24             But we shouldn't have to rely on just the

25      luck of having good people in positions.  Structures







                                                             77
 1      need to be put in place.

 2             But the direct selection of the IG by the

 3      governor, requiring the IG to report -- governor's

 4      office, undermines independence.

 5             A review of best practices nationwide shows

 6      that New York's law falls far short of what the

 7      public should expect.

 8             The nation's Association of Inspectors

 9      General offers model legislation to establish

10      IG offices.

11             We urge you to review that model, and

12      implement measures to enhance New York's IG's

13      independence.

14             Government officials are public servants;

15      they're not royalty or dictators.  They are charged

16      with serving the needs of the public.

17             In order for the public to have confidence

18      that their tax dollars are being used appropriately,

19      and that their public servants are behaving

20      ethically and professionally, there must be

21      independent oversight of all public servants, even

22      the governor.

23             Accountability is the key to maintaining

24      public trust in democracy.

25             State ethics agencies and inspectors general







                                                             78
 1      are central to maintaining that accountability.

 2             The public expects government officials to be

 3      held accountable for effective government, and to

 4      eliminate fraud, waste, abuse, corruption, illegal

 5      acts.

 6             And please act to make these goals a legal

 7      reality.

 8             Thank you for the opportunity to testify.

 9             Ben.

10             BEN WEINBERG:  Thank you.

11             Good morning, Chair Biaggi, and members of

12      the Senate Ethics Committee.

13             My name is Ben Weinberg, and I am the

14      director of public policy at Citizens Union.

15             Citizens Union is a nonpartisan

16      good-government group dedicated to making democracy

17      work for all New Yorkers.

18             For over 120 years, we serve as civic

19      watchdog, combating corruption and fighting for

20      political reform.

21             And we thank you for giving us the

22      opportunity to speak before you this morning.

23             Our previous testimony back in August before,

24      this committee focused on the major flaws of JCOPE,

25      and the need to replace it with a constitutionally







                                                             79
 1      established independent ethics agency.

 2             We won't go into that today, but we hope the

 3      legislature would push for such a solution, and make

 4      other structural and operational improvements to

 5      enforcement.

 6             Today we would like to recommend several

 7      other measures that could improve the system of

 8      ethics oversight in New York.

 9             JCOPE clearly is not the only agency tasked

10      with keeping our government clean.

11             Other relevant agencies were mentioned today:

12      the AG, the Legislative Ethics Committee, the IG, as

13      well as the board of elections, including its chief

14      enforcement officer.

15             So I'll start by something that Rachael

16      mentioned before, which is empowering the attorney

17      general to independently initiate investigations,

18      and prosecute cases involving public corruption.

19             The current state law does not permit the AG

20      to start investigations into ethics violations or

21      public corruption without a direction, request, or

22      permission of the governor or state agency head.

23             Citizens Union, many other groups,

24      attorney general, throughout the years have been

25      stressing that those structural flaws prevent







                                                             80
 1      enforcement of the laws that are on the books, and

 2      allow for troubling ethical scandals that have

 3      rocked Albany for decades.

 4             In fact, the Attorney General Leticia's

 5      investigation into former Governor Cuomo, that has

 6      exposed so many disturbing details, would not have

 7      been conducted if it wasn't for a referral made by

 8      the former governor.  And if it weren't for a unique

 9      political situation that, quote/unquote, forced the

10      former governor into making this referral, the

11      public would have not known about the scope of

12      misconduct exposed in this investigation.

13             This case only stresses the need for the

14      AG to be able to begin investigations on their own

15      accord.

16             And we recommend the legislature to amend the

17      Executive Law to extend the authority in that

18      manner.

19             Restore the state comptroller authority to

20      review state contracts before they are executed.

21             This was mentioned by my colleagues, and by

22      the office of the state comptroller, so I won't

23      repeat that.

24             I will just say, we support restoring that

25      power through state law.







                                                             81
 1             3.  Replacing the Legislative Ethics

 2      Commission with an independent body.

 3             Blair touched on that.

 4             But the Legislative Ethics Commission suffers

 5      from the same problem as JCOPE.  Its leaders are

 6      appointed by the same people that it is the -- the

 7      commission is meant to oversee.

 8             An independent state ethics watchdog with the

 9      power to address ethical issues in the legislature

10      most likely requires amending the state

11      constitution.

12             This newly formed body should replace both

13      JCOPE and the LEC.  And a constitutional amendment

14      sponsored by Senator Krueger and

15      Assemblymember Carroll accomplishes that, and we

16      applaud them for their leadership on this issue.

17             A few other -- several legal solutions that

18      would strengthen the prevention and misconduct, and

19      could assist with the work of oversight agencies:

20             The first is, improving the public

21      accountability of state spending, and reducing the

22      nonspecific funding in the budget.

23             A significant portion of funds set out in

24      every annual budget has really real no criteria for

25      spending, no indication of who controls funding







                                                             82
 1      decisions, and, later, reporting requirements.

 2             In 2019, which we checked -- that was the

 3      last time we checked, that we found $12 billion of

 4      these nonspecific opaque funds in the proposed

 5      budgets.

 6             This invites for misuse and corruption, and

 7      makes it hard for oversight and enforcement bodies

 8      to identify and investigate misconduct.

 9             We recommend a series of reforms for the

10      budget process laid out in our written testimony,

11      including publicly posting comprehensive information

12      regarding the distribution of nonspecific lump-sum

13      funds, including detailed purposes, criteria for

14      spending decisions, requested spending, and other

15      accommodations.

16             Creating a doing-business database to track

17      entities, Rachael mentioned that.

18             We support it wholeheartedly, including

19      setting restrictions on donations from people who

20      appear on that database, including lobbyists.

21             And I would also like to point out that

22      donation bundling by lobbyists and other fundraising

23      intermediates should also be restricted.

24             There are several bills that address

25      different parts of this problem, including







                                                             83
 1      Senator Myrie's bill that passed the Senate, and is

 2      co-sponsored by Chair Biaggi and other members of

 3      this committee.

 4             I'm running out of time, so I'll just mention

 5      a couple of other things that would help prevention

 6      of misconduct.

 7             The first one is, significantly limiting

 8      outside compensation by state legislator.

 9             The 2018 Special Compensation Commission

10      recommended a model based on the congressional

11      model, with a cap on legislative base salary, on

12      income earned from outside -- sorry -- on outside

13      income.

14             Although, as we all know -- probably know,

15      this was eventually revoked by Supreme Court.

16             The legislature should adopt those

17      recommendations.

18             Outside income limitations are really

19      standard ethics practices, and they do help to

20      maintain a clean and transparent government.

21             I think I will end here.

22             Thank you for the commission for -- for the

23      committee convening today's hearing, as well as the

24      August one; and for inviting us to provide public

25      inputs on how to improve ethics oversight.







                                                             84
 1             SENATOR BIAGGI:  Thank you all very much.

 2             I again learned something new just through

 3      your testimonies.  So that is very helpful, and also

 4      the purpose of these hearings.

 5             And so just to begin questioning,

 6      Senator Krueger, and then it will be

 7      Senator Borrello.  And if Senator Hoylman has any

 8      questions.  And then Palumbo, and Boyle.

 9             SENATOR KRUEGER:  Thank you, all three of

10      you.

11             I think I have worked with all of your

12      organizations over the years.

13             So when you were testifying [indiscernible],

14      I have another bill that I hadn't thought about in

15      the ethics framework, but I wanted to ask you what

16      you thought about it.

17             It was a bill I put in fairly late in

18      session, which would say that lobbyists and

19      employees of the governor couldn't be made trustees

20      of independent state boards.

21             And at the time, I did it because I was

22      thinking of naming it the Larry Schwartz Bill.

23             But it struck me that we claim we have all of

24      these independent authorities and boards.

25             I mean, obviously, the SUNY chancellor is the







                                                             85
 1      newest example of the question.

 2             But that there is perhaps something wrong

 3      with the concept that governors can fill them with

 4      the people who already work for him, or her, excuse

 5      me.  We finally have a "her," so I have to make sure

 6      I'm gender-careful here.

 7             But, also, why would we allow lobbyists to be

 8      on our boards?

 9             Isn't there something fundamentally in

10      conflict with the goal?

11             So I hadn't actually run that by anybody.

12             I just put the bill in and thought, I'm not

13      going to get this through Governor Cuomo, but I'll

14      stick it in to be irritating.

15             So what do you think?

16             BLAIR HORNER:  Great idea.

17             RACHAEL FAUSS:  I've taken a look at the MTA

18      in particular, as, you know, part of my role in

19      Reinvent Albany.  And, you know, we support, you

20      know, at a minimum, that state vendors shouldn't be,

21      or people who deal -- who work for companies that

22      are vending with the State shouldn't be, on those

23      bodies, or people who have, you know, reported that

24      they lobby that same entity.

25             I mean, it's basic -- it's basic







                                                             86
 1      conflicts-of-interest issues.

 2             I think when you have this

 3      disclose-and-recuse regime, where someone will

 4      disclose -- you know, in theory, disclose, and then

 5      recuse themselves, you know, you have to ask the

 6      question:  Why is this person serving on the board

 7      in the first place if they're going have to keep

 8      recusing themselves from making those decisions?

 9             So, you know, yes, I think we -- at a

10      minimum, if people have direct conflicts before that

11      agency, they most certainly should not be serving on

12      it.

13             And you can go further than that, as your

14      bill -- it sounds like your bill does.

15             BLAIR HORNER:  I mean, in a sense, you know,

16      it's leverage.  Right?

17             So if you have -- somebody has their hooks

18      into you, and they appoint you to some entity, then

19      you do what they want.

20             And that's not the point of the entity in the

21      first place.

22             All of these boards are supposed to be

23      created as political insulation from the winds --

24      you know, the political winds of the day, and

25      they're supposed to have expertise, and they're







                                                             87
 1      supposed to be independent.

 2             And so I think you're on the right path.

 3             I mean, when we talk about -- and even in

 4      your bill on replacing JCOPE, it's all these

 5      belt-and-suspenders about how you can't be a

 6      lobbyist, you can't be former elected official, you

 7      can't be, you know, the third cousin of any of these

 8      people.

 9             I mean, that's the way we should go.

10             There's 20 million people in the state.

11             I'm sure we can come up with enough

12      independent people to sit on these boards, or maybe

13      we should get rid of them, the boards,

14      [indiscernible], in some cases.

15             SENATOR KRUEGER:  Ben, did you have

16      something --

17             BLAIR HORNER:  I'll just add, the public

18      campaign finance board, you know, one of the newest

19      independent boards, or semi-independent boards, that

20      were established does have a limitation on

21      lobbyists, as well as, if I remember correctly,

22      party officials, former party officials, which is

23      the same situation that would cause a conflict of

24      interest.  And it should be expanded to other boards

25      as well.







                                                             88
 1             SENATOR KRUEGER:  So I've also been doing

 2      some work with Zelnor Myrie and our elections

 3      committee, and what a radical notion.

 4             It turns out you can be an election

 5      commissioner and be running for something at the

 6      same time.

 7             And I was like, excuse me?

 8             That can't possibly be the case.

 9             But apparently it is.

10             So we're trying to fix that through another

11      set of laws.

12             BLAIR HORNER:  Typically, it has an

13      advice-and-consent authority as well.

14             And so, I mean, if you and the House start

15      making the standard to the executive, that no one

16      goes on these boards if they have these problems,

17      you could certainly push back.

18             SENATOR KRUEGER:  Larry, you mentioned -- and

19      I had not heard of this before, the "code of

20      conduct" concept.

21             BLAIR HORNER:  Yes.

22             SENATOR KRUEGER:  So would that have legal

23      standing if you violated it, or is it more a --

24             BLAIR HORNER:  Yes.

25             SENATOR KRUEGER:  -- here, we all know what







                                                             89
 1      the rules of the road are?

 2             BLAIR HORNER:  The state has Section 74 of

 3      the Public Officers Law, which is sort of a code of

 4      ethics now.

 5             The -- one of the things that's been shocking

 6      to me, and it's, you know, sort of, in my opinion,

 7      an example of the growing toxicity of public

 8      service, is the way sometimes people behave:

 9      screaming, ranting, raving, yelling, cursing out

10      public officials in public.

11             I mean, that kind of stuff shouldn't exist

12      as -- if you're a public servant.  Imagine if you

13      had a butler that did that?  You would never hire

14      that person to be your butler.

15             So I think, you know, the idea of adding to

16      the conduct -- the appropriate conduct that we

17      expect from public officials, one that, again, it

18      attracts the council in Europe language -- that was

19      the only one could I find, but there may be

20      others -- would be, I think, a clear indication,

21      that when people are asked to behave a certain way,

22      that they have an opportunity to push back and say,

23      It's not appropriate, I can't do that.

24             So, yes, it would be part of the Public

25      Officers Law.







                                                             90
 1             SENATOR KRUEGER:  Okay.  Thank you.

 2             Thank you, all of you.

 3             SENATOR BIAGGI:  Thank you, Senator Krueger.

 4             Senator Borrello.

 5             SENATOR BORRELLO:  Thank you, Madam Chair.

 6             First of all, thank you all for being here;

 7      I appreciate it.

 8             Time is somewhat limited, but I will -- so

 9      I'm going to kind of focus a little bit on

10      Mr. Horner's request.

11             I think we all can agree, number one, that,

12      you know, everything is broken when it comes to

13      JCOPE, and everything, it needs to be replaced.

14             My concern really is about preserving not

15      just the independence, but also the bipartisan

16      manner in which this is done.

17             You mentioned following the Commission on

18      Judicial Conduct.

19             And that you -- are you suggesting that

20      judges would appoint members to an ethics commission

21      to oversee elected officials?

22             BLAIR HORNER:  Essentially, yes.

23             The way that the joint commission -- I'm

24      sorry -- the Commission on Judicial Conduct's

25      commission is appointed is by the executive and







                                                             91
 1      legislative branches.  So those individuals are not

 2      being -- are not picking the people that are

 3      regulating them.

 4             And so in a mirror-image way, this is

 5      Senator Krueger's bill, the majority would be

 6      appointed by the courts.

 7             Hawaii has this enshrined in their state

 8      constitution.  They have a special court for ethics.

 9      And from that entity comes the ethical -- their

10      commission equivalence in Hawaii.

11             SENATOR BORRELLO:  Well, and I understand if

12      the idea is a mirror image.  But it's not an exact

13      mirror image, because we would be talking about

14      judges that -- aren't elected judges appointed by

15      the governor now picking who would sit on this

16      board?

17             How would you structure that to ensure that

18      these -- the unintended consequence isn't to create,

19      essentially, a ripe environment for partisan

20      political attacks?

21             BLAIR HORNER:  Senator, you are pointing out

22      the obvious weakness in the proposal.

23             It is clearly -- I mean, you know, we're --

24      I think if there needs to be a hearing on the

25      independence of the judiciary, maybe we all should







                                                             92
 1      have it.

 2             But on a sort of a technical level, they are

 3      not regulated -- the judicial branch is not

 4      regulated by the state's ethics laws of the state

 5      ethic -- Public Officers Law in this manner by the

 6      new JCOPE.

 7             And so the way that we -- Senator Krueger's

 8      bill attempts to deal with it, and the way that we

 9      would propose to see it, is that you would strictly

10      narrow the types of people that could be appointed,

11      and you have a public process for how that would

12      happen, so that if there are people that are -- had

13      their hooks placed into them indirectly through the

14      courts, from the governor, that there would be a way

15      for that to be made public and to challenge it.

16             I mean, the hard part is, as you can all know

17      this, is someone has to, at the end of the day, pick

18      these people.

19             And how do you do that, and how do you

20      insulate it as much as possible?

21             So the judicial branch is not technically,

22      you know, under the scope of JCOPE, or its

23      replacement agency.

24             And so that's how we view it -- and we agree

25      with Senator Krueger -- that's how we viewed a way







                                                             93
 1      to deal with the problem, was to have the extra

 2      entity make those choices.

 3             SENATOR BORRELLO:  Yeah, and I agree.

 4             But, ultimately, it's the voters that are the

 5      ultimate judge on ethical behavior.  They should

 6      certainly want to remove anyone from office that

 7      isn't, you know, performing ethically and doing the

 8      job of being a public servant.

 9             As you pointed out, we are public servants.

10             And we certainly went 18 months with a

11      governor that considered himself a dictator.  And,

12      unfortunately, we handed him the reins, and the keys

13      to the car, for those 18 months, pretty much,

14      exclusively.

15             So, you know, with that being said, I want to

16      go back -- idea of, who do we have that has a clear

17      understanding?

18             I mean, you can pull people off the street if

19      you want.  Right?

20             But, ultimately, you can get someone who has

21      a clear understanding of the issue, and how to

22      address it ethically.

23             And I don't see judges, who -- by the way,

24      who -- I think there's a number of issues.  That

25      those that are unelected, those that have very long







                                                             94
 1      terms, 14 years and plus, and then, ultimately,

 2      those whose salaries are controlled by the

 3      legislature and the executive.

 4             So I don't think that's the solution.

 5             Quite frankly, I think more of a transparent

 6      public process, even if those folks are elected

 7      officials, or not, ultimately, there needs to be

 8      some accountability, and not just this, like we see

 9      with JCOPE, where we just snap -- they snap their

10      fingers and, all of sudden, we hear something from

11      them without really having any open, transparent

12      meetings.

13             And even the case of JCOPE, you know, we

14      didn't have a representative from the Senate

15      Majority until, what, March of 2021, which,

16      effectively, gave the governor control over that

17      process for the longest time.

18             So it's definitely broken, but, so far,

19      I haven't seen a solution that kind of creates what

20      you're trying to imagine here without someone having

21      influence.

22             BLAIR HORNER:  Senator, you and I can

23      continue this conversation in January when the

24      legislation starts -- whatever legislation starts to

25      cook up, cooks up.







                                                             95
 1             But I -- look, I agree, I understand your

 2      point.  I've heard it from members.  You know,

 3      I understand it.

 4             And, in the short term, as I mentioned in the

 5      testimony, even if you were to move to a

 6      constitutional amendment, however it ultimately

 7      played out to be stronger, you still have to deal

 8      with, what do you from now until then?

 9             And -- because, at the fastest, that's

10      three years.

11             And I think the public wants, and deserves,

12      a new ethics agency pronto.

13             And we go through that as well, some

14      suggestions on that, where that does rely, more or

15      less, it sounds like, on the kinds of ideas that you

16      have.

17             SENATOR BORRELLO:  Great.

18             SENATOR KRUEGER:  I'm happy to talk to you

19      about my constitutional amendment, which you may or

20      may not have already looked at.  And I am also happy

21      to talk about amendments of it.

22             But it was retired judges, not current

23      judges.

24             SENATOR BORRELLO:  Okay, okay.

25             SENATOR KRUEGER:  So it wouldn't be a







                                                             96
 1      question of, you know, we're paying their salary,

 2      and they have some expectation --

 3             BLAIR HORNER:  What she says.

 4             SENATOR KRUEGER:  -- or, we have some

 5      expectation of their not being independent.

 6             They're folks who were already judges.

 7             SENATOR BORRELLO:  Certainly happy to have

 8      that conversation with you.

 9             SENATOR KRUEGER:  Great.

10             SENATOR BORRELLO:  Thank you.

11             And thank you all for being here.

12             SENATOR BIAGGI:  Thank you.

13             And Senator Hoylman.

14             SENATOR HOYLMAN:  Yes, just following up on

15      that issue of judicial independence, I just wanted

16      to mention that the New York State Commission on

17      Judicial Nomination, which recently put forward a

18      slate of candidates for the current governor to

19      choose from for the court of appeals, is,

20      essentially, dominated by the governor, in

21      conjunction with the Office of Court Administration,

22      the chief judge.

23             So we as legislators have to look at that.

24             You know, years of collaboration, and much of

25      it well meaning, between the executive and the OCA,







                                                             97
 1      to somehow foster greater independence on the part

 2      of the highest levels of the judiciary from the

 3      executive.

 4             It's something that my committee on the

 5      judiciary is looking at, in terms of refining that

 6      commission, and then working, perhaps downward, to

 7      foster greater independence between the judiciary

 8      and the governor.

 9             BLAIR HORNER:  I mean, you know, it's been

10      said, you know, crisis, you know, offers

11      opportunities.

12             And the crisis that we've now had to go

13      through for the last four months does create

14      opportunities to revisit issues, and I think

15      independence is central, generally.

16             I mean, this is outside -- your issues are

17      outside of my -- our area of expertise, but

18      certainly agree with you, conceptually.

19             SENATOR BIAGGI:  Thank you.

20             And Senator Palumbo.

21             SENATOR PALUMBO:  Thank you, Madam Chair.

22             Thank you all for coming.

23             And those are very good points that

24      Senator Hoylman brought up as well.

25             And as we heard from the comptroller, I think







                                                             98
 1      it also comes down to, of course, we can make a very

 2      good system, but it's those involved.  Right?

 3             I mean, you kind of -- Rachael, we kind of

 4      reinvented Albany, you know, a couple months ago --

 5      right? -- because the person we were dealing with,

 6      you know, was a narcissist.

 7             But, you know, at the end of the day, when it

 8      comes to JCOPE, and how about something like, we

 9      have -- because you can't grieve a judge.

10             Judges aren't really -- the Commission on

11      Judicial Conduct, it enforces any untoward conduct

12      by a judge.

13             And a lot of it is pretty obvious, because

14      they're not political, they're not partisan.  And

15      I think that's what the rub is.

16             Senator Borrello mentioned it as well.

17             Because we're trying to figure out, we are

18      political people inherently.

19             So, clearly, you know, we want to avoid,

20      obviously, political hit-jobs, or something that is

21      really unethical on the other side, by an ethics

22      body.

23             So how about the creation of a body -- and

24      I've actually advocated for Senator Krueger's bill

25      on the floor of the Senate.







                                                             99
 1             I think that's really one of the smarter

 2      fixes, or smartest, that we can think of in a

 3      regular basis.

 4             But how about a committee, similar -- bar

 5      association, that would make a referral then --

 6      appellate division, who can, ultimately, issue a

 7      binding decision, like happens with lawyers.

 8             So what say you?

 9             And reconcile that however you would like,

10      any way you can.

11             BLAIR HORNER:  I won't speak for my

12      colleagues, but I've heard, you know, "the trusted

13      source"; you know, you rely on the trusted source to

14      figure things out.

15             And then the question is:  Well, who is the

16      trusted source?

17             So the state bar, for example, lobbies the

18      legislature.  So that's tricky.

19             I've heard about, well, how about the deans

20      of law schools?

21             And that's also tricky, because all the law

22      schools are in universities that lobby the

23      government, and they sometimes get gigantic

24      government contracts.

25             And so -- you know, and so that's a conflict.







                                                             100
 1      Right?

 2             So you end up with these sort of, you know --

 3      at least in my mind, end up with these sort of

 4      Rube Goldberg sort of structures that are relatively

 5      complicated, that rely on transparency standards for

 6      who is eligible, and to the greatest extent

 7      possible, some sort of filter, so that, you know,

 8      it's hard to rig it.

 9             There's enough people looking at it that

10      don't have a stake in the outcome.

11             So -- but I -- you know, the bar, I mean,

12      obviously, is a, you know, reputable organization.

13      I don't think there's anything wrong with that.  But

14      they do have business before the government, and

15      they do, often, are lobbyists.

16             And so when it comes to JCOPE, or the new

17      JCOPE, that regulates the lobbying industry too.

18             And so that issue creates tension.

19             SENATOR PALUMBO:  Sure, sure.

20             And when you think about what happened with

21      the governor -- Rachael, were you about to say

22      something?

23             RACHAEL FAUSS:  Yeah, yeah.

24             SENATOR PALUMBO:  I'm sorry.  Go ahead.

25             RACHAEL FAUSS:  I know, just on the







                                                             101
 1      discussion of, what do we do? what do we replace

 2      JCOPE with? I mean, these are not easy questions.

 3      And, obviously, this is something we've been

 4      wrestling with for a long time.

 5             But I think, you know, there's a few things

 6      to look at.

 7             I mean, there's the, who is appointed; who is

 8      eligible to be appointed? as Blair noted, and many

 9      of you did as well.

10             You know, I know that the hearing that you

11      had in August was fascinating about the Legislative

12      Ethics Commissions and, you know, Alaska and other

13      states, where there's public members.

14             So, you know, there are -- yes, there are

15      people who are regulated, but maybe they're not the

16      balance of the commission.  Maybe they're the

17      minority of the commission.

18             You know, there's redistricting commission

19      models across the country, where you have a pool of

20      people, who, anyone can apply to become a

21      commissioner, and then there are criteria for who

22      can serve.  And then those people can be selected,

23      you know, either randomly, or perhaps by, you know,

24      different parts of government.

25             So there's -- there are a lot of different







                                                             102
 1      mechanisms to diffuse any one regulated entity from

 2      controlling the process.

 3             And I think that that's really looking at how

 4      to put those together in a way that makes the most

 5      independent process, is really important.

 6             And these are some of the things that we have

 7      been looking at and considering.

 8             And I just wanted to, you know, mention that

 9      there are lots of different models for independent

10      ethics oversight.

11             I think, unfortunately, none of them exist in

12      New York now, other than, you know, some on the sort

13      of judicial level.

14             But just from our perspective, you know --

15      you know, retired judges might be one thing.

16             But, you know, the judiciary itself, yes,

17      they're not regulated, but we don't view them as

18      necessarily independent of the governor.

19             And I just would like to, you know, put that

20      as, you know, a concern that we've had.

21             And then when you think about retired judges,

22      you have to think about, potentially, you know, age,

23      diversity, representing the state is potentially an

24      issue too.

25             So those are just some of the considerations







                                                             103
 1      that we've been thinking about in terms of

 2      independent ethics oversight that I wanted to share.

 3             SENATOR PALUMBO:  Sure.  And that almost

 4      overlaps with the same issues with the IG.

 5             Is there a public integrity bureau in the

 6      attorney general's office?

 7             And no appointed IG, who actually had no

 8      teeth anyway, they can't even impanel a grand jury.

 9             So what are they there for, other than it

10      almost seems like political patronage is what it was

11      looking like, when you have a leak of a confidential

12      executive committee decision, or executive decision,

13      on JCOPE, and it ends in, what, a week, or whatever

14      it was.

15             And that's -- that is such -- it's a flagrant

16      violation of law, but they absolutely were

17      terrified, I think, of the executive at that point,

18      and retaliation --

19             BLAIR HORNER:  Well, I thought --

20             SENATOR PALUMBO:  -- because that was his

21      message.

22             BLAIR HORNER:  -- I thought the AG's

23      deposition sort of helped fill in some of the blanks

24      on that, where the former top lawyer -- governor,

25      Linda Lacewell, was saying that the IG is not







                                                             104
 1      allowed, under the law, to investigate the governor

 2      or the governor's top aides.

 3             And so that I think might be the rationale as

 4      to why the AG -- the IG did not follow up on the

 5      JCOPE complaint, because -- which I agree should be

 6      in the slam-dunk category.

 7             You would ask the person who called the

 8      speaker, and say, How did you find out?  And why

 9      didn't anyone on your staff tell anybody that you

10      got contacted?

11             They didn't do that.

12             SENATOR PALUMBO:  Phone records and text

13      messages.  It took a couple hours to put it

14      together.

15             BLAIR HORNER:  And then the IG is the only

16      person who can look into.  Right?  And then the IG

17      is, supposedly, not allowed to do anything.

18             And by the way, again, the current IG, as

19      I understand it, does not view the world that way,

20      and as Nelson Sheingold mentioned in his testimony.

21      Joe Fish didn't either.

22             You can ask former Governor Paterson about

23      that.

24             So, you know, Fish was very aggressive, even

25      with a weak system.







                                                             105
 1             SENATOR PALUMBO:  Sure.  And that's where we

 2      need to make the system -- you don't need to have

 3      that one particular person who is maybe willing to

 4      push the envelope, to go after the governor.

 5      I guess that happened in Governor Paterson's

 6      administration.

 7             BLAIR HORNER:  That's right.

 8             SENATOR PALUMBO:  You need a system that is,

 9      obviously, as good as it can be, and I think maybe

10      even combining those.

11             You know, one last comment.  I'm sorry.

12      I know I'm a little over time.

13             But, just generally, would you -- do you have

14      any comments regarding combining JCOPE, legislative

15      ethics, the whole shooting match, into one body?

16             RACHAEL FAUSS:  We certainly support having

17      one entity that makes the rules for ethical conduct.

18             I think the issue of advisory opinions coming

19      from both bodies, and which one are you supposed to

20      follow, is an obvious problem.

21             So, you know, absolutely.

22             And I think that gets at the issue of people

23      who are -- should not be regulating themselves.

24      So....

25             SENATOR PALUMBO:  Very good.  Thank you.







                                                             106
 1             BLAIR HORNER:  Again, Senator Krueger's bill

 2      sort of does that, but it doesn't deal with the IG.

 3             And so, you know, IGs -- I mean, that's a

 4      great question.

 5             I'm sort of thinking about, well, why would

 6      you need a separate IG if you had what we wanted?

 7             Probably not.

 8             But the IG, you know, when you look at it,

 9      sort of the national level, again, I just suggest

10      you guys take a look at the Association of

11      Inspectors General, which is this national trade

12      association.  You know, they sort of view their

13      world a little bit differently, have different tools

14      to do the investigations.

15             But I certainly, just thinking about it,

16      I wouldn't think that that necessarily precludes it

17      from being in the -- you know, an agency -- a real

18      ethics agency that was independent.

19             SENATOR PALUMBO:  Sure.  A division of the

20      IG, even.

21             BLAIR HORNER:  You may not need it, that's

22      right, if you had the tools to do it.

23             So, I'll stop.

24             SENATOR PALUMBO:  Thank you all.

25             BLAIR HORNER:  Sure.







                                                             107
 1             SENATOR BIAGGI:  Thank you.

 2             Senator Boyle.

 3             SENATOR BOYLE:  Thank you, Madam Chair.

 4             And thank you -- panelists for sharing your

 5      expertise.

 6             And thank you, regarding the inspector

 7      general, in particular.  I think that's a crazy

 8      system that needs to be really overhauled.

 9             I do want to reference Senator Krueger's

10      earlier comment about the election commissioner.

11             I would like to look at that bill, because

12      I thought election commissioners could not run for

13      office.

14             As a matter of fact, we had a case in

15      Suffolk County where Senator Palumbo and I both

16      reside, where our election commissioner tried to run

17      for the state Senate, and was booted off the ballot

18      when they found out he was taking an unpaid leave,

19      or whatever it was.

20             But the courts did not agree.

21             And so I did not think election commissioners

22      could run, but we could get -- bottom of that.

23             They definitely should not be allowed to run.

24                [Simultaneous talking.]

25             SENATOR BOYLE:  And my other -- just a







                                                             108
 1      comment -- if you want to weigh in, fine --

 2      regarding the New York State Attorney General's

 3      referral -- the need for a referral.

 4             I think it's a crazy system that they -- he

 5      or she that are in that position cannot start their

 6      own investigation.

 7             I would harken back, I held a press

 8      conference in -- last August regarding a serial

 9      killing in my district, Gilgo Beach, or, the

10      "Long Island Serial Killer," you may not have heard

11      about it.  Ten -- between 10 and 16 bodies found

12      along the beach.

13             The early parts of that investigation, the

14      then-Suffolk County Police Chief James Burke kicked

15      the FBI out of the investigation.

16             No one -- it didn't make any sense to anybody

17      why you would kick the FBI out of a serial-killing

18      investigation.

19             He -- Burke subsequently went to jail, as did

20      our former district attorney, his top aide.

21             It's not a good situation.  It was not a good

22      situation in Suffolk County.

23             I held a press conference, asking for the

24      attorney general to do an investigation --

25      [indiscernible] an investigation of the early







                                                             109
 1      investigation of the serial killing.

 2             She -- her office was very responsive.  They

 3      called back, said, We would love to, but we need a

 4      referral.

 5             So was the governor going to do it?

 6             Was the comptroller -- the comptroller, he

 7      said, That's not really my area.

 8             So a clear case of potential corruption in a

 9      police department, from the chief, and the district

10      attorney, and the higher ups, and the attorney

11      general could not look into it because she did not

12      have a referral.

13             A perfect example of why this system does not

14      work.

15             Thank you, Chair.

16             SENATOR BIAGGI:  Thank you.

17             BLAIR HORNER:  I'll just mention one quick

18      thing on the -- just, elected officials.

19             The head of JCOPE initially was an elected

20      official.  Janet DiFiore was the elected DA from

21      Westchester.

22             And so, there, I mean, you're regulating the

23      lobbying industry?

24             So there's a lot of things to sort of clean

25      up.







                                                             110
 1             Good point.

 2             Just, FYI.

 3             SENATOR BIAGGI:  Thank you.

 4             I have a few questions, so please bear with

 5      me.  And, again, thank you so much for being here.

 6             I think the theme, and I think it's important

 7      to focus on this theme, instead of another theme

 8      which I'll mention, which is, that the theme I think

 9      is that a lot of what we have created does not work,

10      full stop, period.

11             And so we're trying to either decide if we

12      need new systems or to transform what's in the

13      system already.

14             And I think it's important to have that be

15      the theme with a lot of what we are dealing with,

16      because -- and, Blair, you mentioned it -- JCOPE

17      doesn't work.

18             There's all these different entities, and

19      people are confused.  And it's, frankly, really

20      intentionally designed to lead people down a road

21      that might not end anywhere, might get stalled,

22      might take years to review, and it's really not

23      actually ethical in the essence of it.

24             And so just taking it back to where we are

25      today, which is with a new governor:







                                                             111
 1             Governor Hochul has a series of reforms that

 2      she has mentioned.  It's her transparency platform.

 3             And so there are a few of them.

 4             Agency transparency plans.  Ethics training

 5      for employees.  FOIL becoming a more expedited

 6      process.  And then, personal recusal from certain

 7      entities.

 8             And so just from a general stance on this

 9      issue, what is your assessment of these measures?

10             And, are there any additional steps beyond

11      what the governor has identified that would you like

12      to see, perhaps as a prelude -- State of the State

13      coming up?

14             RACHAEL FAUSS:  I can certainly speak to the

15      agency transparency plans.  I've looked at a number

16      of them.

17             You know, I think they were an important, you

18      know, first step, to at least get them on the record

19      about what their intentions are.

20             And it's -- most of it is just compliance

21      with existing law.  You know, there's been a lack of

22      compliance, in particular, on -- in open data.

23             I would just highlight that, you know, the --

24      there has been an executive order in place since

25      2013, and most state agencies are not fully







                                                             112
 1      complying with that.

 2             You know, I think the governor's directive to

 3      agencies to produce these agency plans had a number

 4      of areas that they could look at.  You know,

 5      retention schedules, FOIL, open-meetings law, open

 6      data; but didn't necessarily mandate that they

 7      address all of those issues.

 8             And it's -- there's not necessarily a kind of

 9      thought that it's going to be an ongoing process.

10             You know, we would like to see agency

11      transparency plans published annually, and updated

12      and, you know, actual metrics for how the agencies

13      are going to be working towards that.

14             You know, the MTA's, to their credit, they

15      actually put in some metrics about how they're going

16      to be, you know, complying with the law.

17             You know, there was a new law the legislature

18      passed, the MTA Open Data Law, that we supported.

19      And they specifically said about when they were

20      going to be complying with it, and the steps they

21      were going to take.

22             So, you know, I think the transparency plans

23      were a good first step, but there is certainly more

24      that can be done to institutionalize them, and make

25      them not just be, you know, a one-off effort.







                                                             113
 1             And, hopefully, the governor will be looking

 2      at that as an option.

 3             BLAIR HORNER:  Just [indiscernible].

 4             Well, you know, I think, since the

 5      governor -- the current governor doesn't have to

 6      sort of defend the previous governor, she's already

 7      taken some good first steps in terms of executive

 8      orders.  There's more she can do.

 9             As the comptroller's office mentioned, they

10      put out a dashboard, to track federal money that's

11      coming in under the -- you know, the various federal

12      bailout programs due to COVID.

13             And, well, why not a dashboard for all

14      spending -- right? -- that somebody could

15      understand.  And you wouldn't have to rely on, you

16      know, necessarily, you know, the various core staff

17      to tell you what's in the budget.  Or Senator

18      Krueger.

19             And so -- and on the recusal issue, the --

20      you know, I think it was great the governor put it

21      out publicly, but it relies really on the internal

22      subordinate lawyers monitoring it, which is a

23      terrible position for them to be in.  And doesn't

24      really -- now, completely understandable, given that

25      you have this car crash called "JCOPE."  But that,







                                                             114
 1      technically, should be the way it works.

 2             You want to have a recusal process, and

 3      you're asking for an opinion, you go -- this

 4      independent agency, and they bless it, and you make

 5      it public, and then it's, like, okay, well, those

 6      guys are watching it; not the people who work for

 7      me.

 8             So I think, you know, there's limits to what

 9      you can do with executive power.

10             I just want to echo Rachael's point.

11             You know, New York City has this whole sort

12      of metric system, where there's an annual report

13      that comes out, that monitors how spending is done,

14      and whether or not the agencies are meeting

15      performance standards.

16             You really use that at the state level.

17             It's hard to know, really, what's going on.

18      And sometimes things get circumvented under

19      New York State law.

20             Sorry, I digress.

21             There's -- it's supposed to be an independent

22      evaluation of the state's tobacco control program;

23      and yet, you know, they haven't put out a report

24      since 2017.  They're always under pressure from the

25      executive to sort of, you know, play ball.







                                                             115
 1             And so it's not independent.  Right?

 2             So there's -- there are so many things that

 3      are happening in state government.

 4             Let me just stop there.

 5             The current governor, though, must have -- be

 6      overwhelmed with all the incoming.

 7             And so I have a million ideas, but whether or

 8      not she can pick and choose the best ones, I guess,

 9      would be up to her.

10             But just to react to your point, on her

11      executive actions, a dashboard on spending, DOB

12      could do that.  And, metrics, the agencies

13      presumably have that, and they can publish that.

14             And so there's things I think she can do with

15      her executive power to go even beyond what she's

16      done so far.

17             So, more.  We want more.

18             SENATOR BIAGGI:  Ben, did you have any --

19             BEN WEINBERG:  No.  I think [simultaneous

20      talking; indiscernible] --

21             SENATOR BIAGGI:  Okay.

22             That's actually very helpful.

23             I think that a lot of what we do every day

24      could be better served by having metrics and

25      databases.  And I think you're right, to expand it







                                                             116
 1      beyond just COVID, because there really is no way to

 2      track a lot of, besides, of course, downloading

 3      Senator Krueger's mind into a jump drive, which

 4      I wish that we could do because my life would be

 5      much easier.

 6             BLAIR HORNER:  We would need more than one

 7      thumb drive, though.

 8             SENATOR BIAGGI:  But it makes it very hard,

 9      even --

10                [Simultaneous talking.]

11             SENATOR BIAGGI:  -- but, true, you have a set

12      of knowledge.

13             But having an ability to even be able to say,

14      well, we put money into the budget for this program,

15      and how many people did it serve?  And what was the

16      amount that we actually spent?  And what have we

17      actually not spent, and what's left over, and where

18      does it go?  And what should we not actually

19      allocate next year?

20             It's very common sense, and yet -- and a lot

21      of businesses do it.  And I know, actually, mayors

22      across other cities do it, like in Boston.

23             But we do need to bring it to the state of

24      New York, because it also allows us, as legislators,

25      to do our job better, and we can redirect funds, and







                                                             117
 1      also understand where there is lots of pitfalls.

 2             So I don't mean to belabor the point, but

 3      it's really something I've become almost obsessed

 4      with.  And I really am glad that it's coming up

 5      several times today.

 6             We talked a lot about the inspector general,

 7      and so inspector general reform is clearly a very

 8      important theme of this hearing.

 9             And, of course, I mentioned the bill that

10      I had introduced, with a different reporting

11      structure.

12             Also, Governor Hochul has mentioned that she

13      is rethinking the appointment process of the

14      inspector general, which is, of course, appointed by

15      the governor.

16             And so I think, you know, beyond what we've

17      already discussed today, which is the bill that

18      allows for the legislature to have a role, as well

19      as the secretary to the governor, and, potentially,

20      the comptroller, is there anything beyond these

21      structural changes, with regard -- IG, in the

22      appointment process that you would like to see for

23      the inspector general, that is missing from the

24      bill, or that we maybe have overlooked?

25             RACHAEL FAUSS:  Well, I have yet to review







                                                             118
 1      your bill, so apologies.

 2             SENATOR BIAGGI:  That's okay.

 3             BLAIR HORNER:  But I said it in my testimony,

 4      you know, bars on the types of people who can serve.

 5             That's not in there.

 6             I think that's crucial, in addition to sort

 7      of a, you know, reporting to more than just the

 8      executive.  So....

 9             SENATOR BIAGGI:  Right.

10             BLAIR HORNER:  Yeah, I mean, an active

11      advice-and-consent process, either by the Senate or

12      by both houses, is, I think, you know, a way to sort

13      of deal with it; plus, as Rachael just mentioned, a

14      restriction on the type of people that can be

15      advanced.

16             SENATOR BIAGGI:  Right.

17             Okay.  I think that makes lots of sense.

18             I think also a theme of the IG's office,

19      specifically, is this lack of transparency, which is

20      why I'm disappointed that they're not here today,

21      because having a hearing allows us to talk to them

22      and to understand:

23             What do you do?

24             What is going on in there?

25             What's backed up?







                                                             119
 1             What are things that you want the legislature

 2      to have help on?

 3             So I hope that that changes in the future.

 4             But what the Hochul Administration has done

 5      is pledged to release all of the findings of the

 6      future and past investigations by the IG office,

 7      dating back to 2020.

 8             And I think the "Times Union" mentioned that,

 9      basically, what this means is that there is a

10      three-year gap -- last known action taken by the

11      inspector general under Governor Cuomo.

12             Do you see this as being a concern?

13             Are there additional steps that the IG's

14      office can take to increase accountability, but also

15      transparency?

16             And -- because releasing reports is one

17      thing, and that should be a given.

18             But what else can they do proactively without

19      the legislature and our legislation requiring them

20      to do it?

21             RACHAEL FAUSS:  I don't know if they do an

22      annual report, but I think a lot of agencies do -- a

23      lot of oversight agencies do.  I mean, JCOPE

24      actually does.

25             But, you know, I think something that we've







                                                             120
 1      noted with a lot of agencies, where we, you know,

 2      submit complaints, is they kind of go into this

 3      black box and you have no idea where they go.

 4             It's like, okay, well, we made a complaint --

 5      board of elections, or we made a complaint to JCOPE.

 6             And, you know, just even having aggregate

 7      data about how many complaints are received; how

 8      many, you know, metrics, again, as you were saying,

 9      about the office's performance, that could be

10      helpful.

11             So, maybe, I think looking at annual

12      reporting requirements could be interesting,

13      perhaps.

14             SENATOR BIAGGI:  I think that's a great idea.

15             BLAIR HORNER:  I think the model legislation

16      is worth looking at.

17             I mean, just by the sheer volume of what the

18      model legislation, as compared to this sort of

19      three-paragraph version in New York.

20             By the way, there are other inspectors

21      general too.  I mean, you have the MTA, you have

22      Medicaid.

23             And so there should be some way to sort of

24      look at this sort of holistically.

25             And so I -- I mean, I just suggest that you







                                                             121
 1      take a look at the tenure of Joe Fish.

 2             I mean, here's a guy who made it work, in our

 3      opinion, and he is very, very aggressive.  And he

 4      had the sort of structure that currently exists, and

 5      yet pumped out, I don't know, scores of reports.

 6      And he was very influential in looking at some of

 7      the pay-to-play activities around "casinos"

 8      decisions back in 2010, I guess it was.

 9             SENATOR BIAGGI:  Right.

10             Okay.  That's helpful.

11             SENATOR KRUEGER:  [Inaudible.]

12             SENATOR BIAGGI:  Yes, please,

13      Senator Krueger.

14             SENATOR KRUEGER:  Was there a statute change

15      around the IG between then and now?

16             BLAIR HORNER:  I don't recall there being

17      one?

18             SENATOR KRUEGER:  Or it's just different

19      interpretation about what the job description --

20             BLAIR HORNER:  Well, to Governor Paterson's

21      credit, I presume.  Right?

22             I mean I met with Fish when he first started,

23      and he had been involved in, I guess, the commission

24      dealing with Serpico back in the day.

25             I mean, he was a guy late in his career.  He







                                                             122
 1      was not going to be pushed around.  No one was going

 2      have their hooks into him.

 3             And he's, like, I'm not ending my career in

 4      this job, and then not doing what I'm supposed to

 5      do.

 6             So he just stood up -- pressure, as far as

 7      I could tell.

 8             SENATOR BIAGGI:  I think that that's a good

 9      influence on all of us.

10             Okay.  I'm going to skip over, just because a

11      lot of what my questions are on the IG were regard

12      with the bill, so we'll talk about that, hopefully,

13      afterwards, and I'm sure there will be some

14      amendments that can make it better.

15             Let's just see.

16             Okay.  I think there's just two final

17      questions, under the "attorney general" category.

18             So the AG runs something called "New York

19      Open Government," which is fascinating, if you take

20      a look at it, but it exists.  And it's really,

21      essentially, this data aggregation for all of the

22      data that is released publicly by New York State

23      agencies.

24             For those who are watching, who don't know,

25      you should definitely check that out.







                                                             123
 1             Can you talk about your experience with

 2      open -- with this Open Government database, and

 3      whether it's actually useful at all?

 4             I know it hasn't been updated for years.

 5             So what is your experience working with this

 6      database?

 7             What should we be doing with this database,

 8      and how can we actually use it?

 9             BLAIR HORNER:  Let me just mention one quick

10      thing.

11             I worked -- this idea came from

12      then-Attorney General Andrew Cuomo --

13             SENATOR BIAGGI:  That's -- oh, yes.  I forgot

14      to mention that irony.

15             BLAIR HORNER:  -- and I headed it up.

16             So I can tell you, it was a brutal experience

17      just getting access -- information that was publicly

18      available.

19             The idea was to have one-stop shopping.  The

20      problem -- and then it evolved over time.

21             And once it got past these sort of

22      technical -- like, I'm like Koko the gorilla when it

23      comes to technology.  Right?  So in the beginning

24      I dealt with that part, and then somebody else dealt

25      with it, and I went back to working at NYPIRG.







                                                             124
 1             The problem is, always, you're relying on the

 2      state agencies to get you the data.  And I don't

 3      know what the status is in terms of their resources.

 4      But that is always going to be the problem because

 5      they don't have any independent authority currently

 6      to collect the data or require that the data be even

 7      accurate.

 8             SENATOR BIAGGI:  Right.

 9             BLAIR HORNER:  But it was supposed to be

10      one-stop shopping, and so you can look at, you know,

11      charities' information, contract information,

12      campaign contributions.  The sort of the backbone of

13      it was really the -- sort of the legislative side to

14      it, the bills.

15             And so -- and then from there it was

16      lobbyists, campaign contributions.  Then you looked

17      at contracts, and, et cetera.

18             And so it was -- so, yeah, I mean, I use it.

19             But it is only as useful as the agency has

20      resources for it, and the accuracy and

21      up-to-datedness of the data that it collects.

22             BEN WEINBERG:  I'll just add, you know, in

23      many cases, it is more useful than how the agency

24      presents the same data.

25             The state board of elections is the most







                                                             125
 1      obvious situation, where their public database of

 2      contributions is almost impossible to navigate

 3      through.  And the AG system is just more

 4      user-friendly.

 5             But as Blair mentions, really, I think a more

 6      comprehensive solution for that is a

 7      legislative-solution model like New York City has,

 8      where, you know, the Open Data Law in New York City

 9      mandates that all agencies send, you know, a variety

10      of databases directly to one hub.

11             And that is, honestly, I think revolutionized

12      the way that the data is seen and tracked in

13      New York City.  And that helps us in good-government

14      groups, that helps the press, and that helps other

15      watchdogs.

16             RACHAEL FAUSS:  I just would reiterate, we

17      think there's a lot of potential with the -- this

18      database and for one-stop shopping, as Blair said,

19      because, you know, if you're trying to connect the

20      dots on state spending, the best way to do it is to

21      search one place.

22             You know, say there's a state vendor and

23      you've got a concern about them, you just search one

24      place and get all the information about, you know,

25      what contracts do they have, what campaign







                                                             126
 1      contributions are they making, what bills are they

 2      lobbying on, et cetera.

 3             That's -- that should -- it should be easier

 4      for the public and the legislators to connect the

 5      dots, and the potential is really there.

 6             And I think that, you know, the exercise of

 7      the AG's office doing that, and -- is really

 8      important because it kind of points out the flaws in

 9      the data.  Like Ben said, the board of elections

10      data is bad.

11             The AG has made it more user-friendly.  But

12      there's also, you know, data-integrity issues,

13      where, you know, in some places, looking at the

14      campaign contribution data, you will find the same

15      vendor spelled four different ways.

16             IBM Corp.  IBM Corp.  IBM.

17             It's just -- it's kind of maddening, and

18      I think it's something that I -- not a lot --

19      you know, very much in the weeds, but it's kind of

20      crucial to integrity, and anticorruption efforts, as

21      if -- if your data is terrible, it's going to be

22      harder to -- you know, for the enforcement agencies

23      to do their job.  So....

24             SENATOR BIAGGI:  Right.

25             That's pretty remarkable, actually.







                                                             127
 1             And just for the record, because, you know,

 2      being candid, obviously, most important, I did not

 3      even know that this database existed until recently.

 4             And it's actually something that I have been

 5      talking about.  But to see that it exists, so that

 6      the infrastructure is at least there, and that we

 7      can deal with what we've got and make it better, is

 8      really, frankly, very promising to me.  And do

 9      I think it would be very useful to a lot of

10      legislators, as well as the public.

11             So this is something that I'm really excited

12      to work on, which sounds so silly, but it really,

13      I think, can transform the way we actually work and

14      make decisions.  And that's the whole point at the

15      end of the day.

16             I believe that that is all of the questions

17      that I -- oh, I actually have one final question.

18             Apologies.

19             You had mentioned this, but I just want to

20      get this on the record very clearly, when we were

21      talking about the inspector general's powers, and

22      who they may investigate.

23             And so, Linda Lacewell, the former

24      DFS superintendent and aide to Governor Cuomo --

25             BLAIR HORNER:  The minister of defense.







                                                             128
 1             SENATOR BIAGGI:  -- among other things --

 2             What's that?

 3             BLAIR HORNER:  The minister of defense, as

 4      you may recall.

 5             SENATOR BIAGGI:  Yeah, minister of defense,

 6      amongst other -- yes, that's a really nice way to

 7      put it.

 8             Thank you for doing that for me.

 9      I appreciate that.  I had a loss of words there.

10             -- she had testified in the AG's

11      investigation, that the inspector general is legally

12      prohibited from investigating both the governor and

13      the secretary -- governor.

14             And so just to make it very clear on the

15      record, for the three of you:

16             Do you believe that the inspector general may

17      investigate the governor or the secretary --

18      governor should the need arise?

19             And do you believe it would be a conflict of

20      interest for the inspector general to investigate

21      the person who appoints them?

22             Two separate questions.

23             RACHAEL FAUSS:  I haven't looked at those

24      particular legal issues, but, obviously, if all that

25      is true, that is a massive problem, because that's







                                                             129
 1      their job.

 2             So, you know, I would assume that the

 3      person -- you know, Linda Lacewell's statement is

 4      accurate.  And I think that -- it's alarming and

 5      extremely troubling.

 6             And, obviously, your legislation to look at

 7      the IG and fix it, I mean, that's perhaps something

 8      to look at, and make sure it's addressed in that.

 9             BEN WEINBERG:  I'm not a lawyer, nor a

10      counsel on this issue.

11             I would hope that that statement was made

12      after the legal counsel telling her that that is the

13      situation.

14             But as Rachael said, if that is the case, it

15      makes the whole position quite redundant and

16      pointless.

17             BLAIR HORNER:  Well, I mean, there's a logic

18      to it.  Right?

19             She reports -- people, in the case of the

20      inspector general, so how can she investigate them?

21             Now, again, as we mentioned before, Joe Fish

22      did, and the current IG says she can.

23             So it may not be a legal issue as much as the

24      way it's set up that creates this inherent.

25             And by the way, it's also convenient, because







                                                             130
 1      it might have been a convenient legal interpretation

 2      to keep the IG from following up on the book leak in

 3      JCOPE, just, coincidentally.

 4             So I -- you know, I think that -- what the

 5      law is, it certainly seems fuzzy enough that you

 6      guys recommend we clean up.  But I think the whole

 7      issue of having the IG report -- secretary,

 8      effectively, the governor, is a fundamental flaw.

 9             SENATOR BIAGGI:  Yep.  I happen to agree.

10             Thank you all so much.

11             As always, we really appreciate the time that

12      you take, the care that you take, and also, really,

13      the dedication to ethics, and to supporting us, in

14      making sure that we do our jobs as best as possible.

15             So I have a lot of hope for the 2022

16      legislative session, and I look forward to working

17      with you all.

18             BLAIR HORNER:  One month.

19             SENATOR BIAGGI:  One month.  Exactly.

20             Happy holidays.

21             Thank you so much.

22             SENATOR KRUEGER:  Thank you.

23             SENATOR BIAGGI:  All right.

24             All right.  So next up will be, actually, a

25      virtual panel, and we will be hearing from a







                                                             131
 1      legislator from California, Scott Wiener, and also

 2      his legislative counsel, which is the person who

 3      serves on -- excuse me -- serves as legislative

 4      counsel to the ethics committee that he also serves

 5      on as well.

 6             And it's noon, so that's about right.

 7             Okay.  Why don't we take just a 15-minute --

 8      10- to 15-minute break.

 9             Let's take a five-minute break for the

10      restroom, and come back at 12:20.

11             Thank you.

12             Okay.  So we're not going to take a break.

13             I'm glad that the -- this is so fun.

14             Okay.  That's great.

15             I'm glad that....

16             Okay.  Whenever you're ready.

17             CA SENATOR SCOTT WIENER:  We're ready?

18             SENATOR BIAGGI:  Yes.  Good morning to you,

19      and good afternoon to us, because -- since you're

20      three hours behind.

21             I'm very grateful for you to join us today.

22             And, also, just before we begin, are we

23      waiting for your counsel, Erin Peth?

24             CA SENATOR SCOTT WIENER:  No, she's here.

25             SENATOR BIAGGI:  She's there?







                                                             132
 1             Okay, great.  That's wonderful.

 2             All right.  Well, thank you very much for

 3      joining us.  We're really grateful to have you.

 4             I often joke in New York, no matter what

 5      we're doing, California seems to lap us, unless

 6      Senator Hoylman seems to be on to what's going on in

 7      California, and then also gives a lot of

 8      competition.

 9             So I know you have a nice -- a good friend

10      here as well.

11             But we're really grateful that you joined us,

12      to share what's going on in California, especially

13      because your ethics rating in your state is actually

14      much higher than New York's.

15             So we look forward to hearing your testimony,

16      and also engaging in some dialogue afterwards.

17             CA SENATOR SCOTT WIENER:  Great.

18             Thank you, Madam Chair, and committee

19      members.  And hello to my friend and law school

20      classmate, Senator Hoylman.

21             So I'm Scott Wiener.  I have the honor of

22      serving on the California State Senate, representing

23      San Francisco and the northern part of San Mateo

24      County.  I've been in the Senate since 2016.

25             I serve as chair of our Senate Legislative







                                                             133
 1      Ethics Committee, and I also chair our housing

 2      committee.

 3             So thank you for inviting me today.

 4             I will be focusing on our Senate ethics

 5      requirements.

 6             I'm also joined by Erin Peth, who is the

 7      chief counsel to our committee on legislative

 8      ethics.  And before joining the Senate, Ms. Peth was

 9      the executive director of California's Fair

10      Political Practices Commission (FPPC), which is our

11      statewide ethics agency with broad oversight over

12      government ethics issues, as well as campaign

13      finance issues.

14             So Ms. Peth is very expert in these issues,

15      and will be able to help out with -- if there are

16      some questions that I can't answer.  She has very,

17      very broad knowledge.

18             So California has a robust set of ethics

19      requirements for government officials.  We have a

20      layered approach to our ethics rules.  Some are in

21      our state constitution, and statute and regulations

22      issued by the FPPC, and internal agency rules.

23             The Senate, we have adopted specific internal

24      ethics rules to cover all of our staff members, and

25      those provisions are contained in our standing rules







                                                             134
 1      and in our Senate Standards of Conduct.

 2             That calls for the creation of a legislative

 3      ethics committee, which is comprised of

 4      six senators, at least two have to be from each

 5      party, and the chair and vice chair can't be from

 6      the same party.  The two leaders are president

 7      pro tem and the minority leader are ex officio

 8      members.

 9             We receive complaints related to members or

10      staff.  We review those complaints.

11             Sometimes we hold public hearings.

12             Sometimes a public hearing is not warranted,

13      and we can issue anything ranging from a warning or

14      admonition, to stripping a member of various rights

15      or privileges, a reprimand, a censure, and,

16      potentially, expulsion.

17             If the respondent is a member of our staff,

18      then we transmit our findings to the rules committee

19      for appropriate action.

20             We, also, California law and our standards

21      require all senators and staff to attend a

22      comprehensive ethics training once every two years.

23             Also, each senator is required to have an

24      individual review session with Ms. Peth every

25      two years; so, one-on-ones, in addition to the







                                                             135
 1      larger group trainings.

 2             I know there has been some concern in

 3      New York about leaks from ethics hearings, as

 4      I understand it.

 5             We have very, very strict rules for our

 6      ethics committee about not disclosing information.

 7      And any member who discloses information is subject

 8      to discipline.

 9             So we take confidentiality very seriously,

10      and our members have respected it.

11             Our ethics committee work very, very well

12      together in a bipartisan nature.

13             I'm a liberal Democrat from San Francisco.

14      My -- our vice chair is a very conservative

15      Republican from Bakersfield.  And the two of us

16      really work hand in glove in overseeing the

17      committee, and we talk regularly.  And it's been a

18      good bipartisan, often consensus-driven, committee,

19      which is really important in the ethics arena.

20             The standard of conduct in the Senate

21      would -- it contains 12 standards, and they were

22      adopted in 2014 after three different senators faced

23      criminal prosecution in that year for separate

24      incidents.

25             It was not best year for the California State







                                                             136
 1      Senate, 2014; but we've moved past it, and we did

 2      adopt these very detailed rules.

 3             The standards really have two fundamental

 4      principles:

 5             The first is, that holding public office is a

 6      public trust;

 7             And the second, is that trust is eroded by

 8      actions that appear to place the official's private

 9      interests over public interests.

10             The standards are very clear that appearance

11      is also important, even if a rule hasn't been

12      violated.

13             And I think we all know that in public

14      service, that, you know, appearance of propriety is

15      quite important.

16             The standards establishes zero-tolerance

17      policy for unethical behavior, and also create a

18      duty to report violations.

19             The standards strive to have all senators and

20      staff be independent and impartial, and to make

21      decisions through the established process of

22      government, and not to use public office, of course,

23      to obtain personal benefits.

24             So, again, thank you for the opportunity

25      today, and Ms. Peth and I are happy to answer any







                                                             137
 1      questions that you may have.

 2             SENATOR BIAGGI:  Thank you very much,

 3      Senator, and we're going start with Senator Hoylman.

 4             And, really, I just appreciate also your --

 5      the words that you mentioned about your working

 6      across the aisle.

 7             I think it is needed probably more than ever,

 8      and it's a really good inspiration to those of us in

 9      New York; so, I want to give you credit for that.

10             Senator Hoylman.

11             SENATOR HOYLMAN:  Hello, Senator Wiener.

12             CA SENATOR SCOTT WIENER:  Hello, Senator.

13             SENATOR HOYLMAN:  It's good to see you.

14             You know, we went to law school together many

15      years ago, and I try to emulate Senator Wiener from

16      the East Coast.  He's kind of like my West Coast

17      counterpart, except he's much taller, and represents

18      a lot more people.  I think you have a million

19      constituents, I think, the last time I checked.

20      Your districts are very large out there.  But we've

21      worked together on a lot of legislation.

22             But I wanted to ask you about outside income,

23      and whether that is an issue in California.

24             Does the California State Legislature allow

25      your members to have part-time jobs outside of their







                                                             138
 1      legislative duties?

 2             CA SENATOR SCOTT WIENER:  I think under

 3      limited circumstances.  But Ms. Peth actually could

 4      probably comment on that in a more detailed way.

 5             I take the approach, I don't allow myself to

 6      have any outside income, period, even if it's

 7      allowed.

 8             But there are -- you know, it is allowed

 9      under certain circumstances.

10             SENATOR HOYLMAN:  I was just wondering if

11      that's something the legislature has looked to

12      address.

13             I've carried legislation for a number of

14      years that would, essentially, limit it to things

15      like teaching courses; essentially, no more than

16      around 10 percent of your base income, modeled after

17      the United States Congress which has strict rules

18      around that.

19             Also, my legislation would prohibit the

20      practice of law by members, because I felt, like,

21      you know, you can't have both a duty to your client

22      and a duty to your constituents, particularly when

23      one is privileged.

24             Do -- are -- is the practice of law -- and,

25      again, if your counsel is there -- is the practice







                                                             139
 1      of law permitted by legislation?

 2             CA SENATOR SCOTT WIENER:  It is, but Ms. Peth

 3      can elaborate further.

 4             I think we have -- I think we're fairly

 5      permissive.

 6             SENATOR HOYLMAN:  Got it.

 7             Has it led to --

 8             CA SENATOR SCOTT WIENER:  Ms. Peth can

 9      comment further.

10             ERIN PETH, ESQ.:  Yes, so to echo what

11      Senator Wiener was saying, it is allowable for our

12      members to have outside employment.

13             As a practical matter, we do have a full-time

14      legislature in California, and I think, you know,

15      they are, obviously, incredibly busy people.

16             So we do -- but we do have some members who

17      are members of the bar, who have retained, you know,

18      some sort of position in a law firm.

19             We obviously do have conflicts-of-interest

20      provisions.

21             So those outside sources of income could

22      arise in a conflict-of-interest situation, depending

23      on what decisions the members are involved in.

24             SENATOR HOYLMAN:  Thank you.

25             No, that's interesting.







                                                             140
 1             I wanted to know if New York was an outlier

 2      in that regard.

 3             It sounds like --

 4             CA SENATOR SCOTT WIENER:  I have a feeling

 5      that -- I mean, so many state legislatures are

 6      part-time.  There is the whole other issue of, you

 7      know, especially large states, like Texas, that have

 8      part-time legislature.  And you're forcing people to

 9      have outside employment, and that can create a

10      conflict.

11             SENATOR HOYLMAN:  Right.

12             And that's the problem I think a lot of our

13      colleagues, you know, we're all under economic

14      pressure at home.

15             Our salaries are reflective of, you know,

16      I think more of a part-time legislature, on some

17      respects, than a full-time legislature.  And so our

18      members who are lawyers, and who have private

19      employment, you know, need that supplemental income.

20             I wish that, in New York State, we could do

21      what the city council has done here, which is have

22      an independent commission, fully, that sets our

23      salaries, rather than make it subject to political

24      horse-trading, which is, I think, sadly what's

25      happened in New York for decades.  And even in the







                                                             141
 1      last iteration of an attempt at a commission for a

 2      salary, we ended up, Senator Wiener, and like

 3      lawsuits, and some sort of halfway approach, where

 4      the legislators were afforded a salary, but only

 5      partially.  And I think there may still be an appeal

 6      around that issue.

 7             So it's -- like, to a finer point, which

 8      is -- a finer -- to drill down on that, how are your

 9      salaries set in California?

10             CA SENATOR SCOTT WIENER:  Yeah.  So we have a

11      citizens commission, I can't remember the formal

12      name, that sets salaries for legislators and for our

13      statewide constitutional officers, like governor,

14      attorney general, et cetera.  And once a year there

15      is a cost-of-living adjustment.

16             And so we just -- we get a memo, to your --

17      saying, there's no increase, or you're going to get

18      a 2 percent increase, or whatever the case may be,

19      and, there can be shenanigans.

20             Our last -- when Governor Schwarzenegger was

21      governor, they -- he got the citizens commission to

22      take a wrecking ball to legislative salaries during

23      the last recession, and to really take a big whack

24      in reducing those salaries.  That was just a

25      political attack by Governor Schwarzenegger.







                                                             142
 1             But, that aside, I think it works reasonably

 2      well.

 3             SENATOR HOYLMAN:  Thank you.

 4             Senator Biaggi, I think it's something we

 5      should --

 6             SENATOR BIAGGI:  I agree.

 7             SENATOR HOYLMAN:  -- we should look at, to

 8      really, fully, remove the pressure of outside income

 9      on our members who, all in all, are trying to do the

10      right thing and provide for their families.

11             But there's -- it's a very expensive state,

12      and particularly city, to live in.

13             CA SENATOR SCOTT WIENER:  I think it's --

14      I think it's incredibly important.

15             When I first moved to San Francisco in 1997,

16      the San Francisco Board of Supervisors, which is

17      more than a full-time job, given the intensity of

18      this great city, they made $24,000 a year, and only

19      the voters could set the salary.

20             And so voters, at one point, finally raised

21      it to 36,000.

22             But, ultimately, the solution is a -- the

23      charter amendment to transfer it -- a civil service

24      commission, and so the board now actually gets a

25      real salary.







                                                             143
 1             SENATOR HOYLMAN:  Good seeing you, Scott.

 2             CA SENATOR SCOTT WIENER:  You too, you too.

 3             SENATOR BIAGGI:  Thank you, Senator Hoylman.

 4             And, actually, I could not agree more with

 5      that approach, and I think we should do something

 6      about it; so we must.

 7             Senator Borrello, please.

 8             SENATOR BORRELLO:  Thank you, Chairman --

 9      Chairwoman.  Excuse me.

10             It's the mask, I promise.

11                [Laughter.]

12             SENATOR BORRELLO:  Senator Wiener, thank you

13      very much for coming on and speaking with us.  We

14      appreciate it very much.

15             I thought it interesting that you pointed out

16      that you are co-chair of this ethics commission; is

17      that correct?

18             CA SENATOR SCOTT WIENER:  No.  I'm the chair,

19      and then my Republican colleague is vice chair; but

20      we operate together.

21             SENATOR BORRELLO:  Right.

22             So -- and you said that you're obviously a

23      liberal Democrat and he's a conservative Republican.

24             CA SENATOR SCOTT WIENER:  "She."

25             SENATOR BORRELLO:  She, she.  Excuse me.







                                                             144
 1             And that this is really worked very well in

 2      that model.

 3             And that -- so, you know, Chairwoman Biaggi

 4      mentioned that California is far and above New York

 5      as far as ethical standards.

 6             So would you attribute the bipartisan nature

 7      of your commission as being pivotal to that, you

 8      know, based on what you said?

 9             CA SENATOR SCOTT WIENER:  Well, I'll be

10      honest, our legislative ethics committee had not

11      been constituted for several years, because I don't

12      know if it was because there weren't complaints

13      coming in, or what the reason was.  But -- and it

14      was only about a year ago, or earlier this year,

15      that our Senate leader reconstituted the committee.

16             So if we're good on ethics, and we try hard,

17      that did predate the reconstitution of the ethics

18      committee.

19             So I don't think that that bipartisanship is

20      the reason that we have the culture that we have.

21             I think we have strong ethics rules, which

22      is -- and laws, which is probably I think the most

23      fundamental issue.

24             But having had -- there have been -- and

25      I can't get into the details because it's







                                                             145
 1      confidential -- you know, complaints that come in,

 2      it has been really helpful to have that bipartisan

 3      working relationship in the ethics context.

 4             I try to have it in other contexts as well,

 5      and sometimes it works, sometimes it doesn't.

 6             But on the ethics front, I think, you know,

 7      we have tried hard for it to work.

 8             But I also think that it has to do with,

 9      also, like the personalities of who is on the

10      committee from both sides, because we can, you know,

11      imagine situations where, for example, certain

12      members of Congress, you know, that we all know, we

13      might not want to have on that kind of committee.

14             And we -- you know, so having the right

15      personalities of people who really are willing to

16      set aside partisanship in the ethics context, and

17      really just look at the facts, and try to work

18      together, because it does build confidence.  Right?

19             If you have a unanimous consensus that this

20      was a violation, or this wasn't a violation; or it

21      was a violation but it was minor, so it just

22      warrants a private, you know, admonishment letter;

23      or this is so significant, it, you know, needs a

24      public hearing, and -- if do you that unanimously,

25      it's very powerful, and it builds confidence in the







                                                             146
 1      result.

 2             SENATOR BORRELLO:  Okay.  Thank you.

 3             With that being said, then, you've got

 4      yourself, you've got a bipartisan membership in this

 5      commission.  They're elected officials, they're

 6      sitting legislators.

 7             And what's the overall makeup of your state

 8      legislature, like, Republican versus Democrat?

 9             CA SENATOR SCOTT WIENER:  We have, in both

10      houses, more than 75 percent Democratic members.

11             So in the Senate it's 31 out of 40 are

12      Democrats.  In the Assembly it's -- is it 60, or 61?

13             We've had some resignations recently, and

14      some -- not for ethics reasons -- and we have some

15      vacancies.  But there were, I think, 61 in the

16      Assembly.

17             So it's a strong majority.

18             It's -- we have, on our ethics committee,

19      it's four Democrats and two Republicans, in

20      addition -- two ex officios who are our two leaders.

21             And it requires a two-thirds vote for us to

22      take action as well.

23             So, yeah.

24             SENATOR BORRELLO:  So despite having super

25      majorities in both houses, you still have what would







                                                             147
 1      be considered a balanced ethics commission, based on

 2      that, and that seems to have worked well for you?

 3             CA SENATOR SCOTT WIENER:  Yeah -- yeah,

 4      the -- yes, it does work well.

 5             SENATOR BORRELLO:  Great.

 6             Just one final question, and I know my time

 7      is almost up.

 8             Do you have an actual vehicle to remove an

 9      elected official within your law?

10             I mean, I think one of the troubling issues,

11      and I'm speaking more as a former local government

12      official, that there's just no -- there's no vehicle

13      to remove an elected official, except for the

14      governor.

15             CA SENATOR SCOTT WIENER:  We have the power

16      in our constitution, each house determines the

17      qualifications of members, and if someone is to be

18      seated.  And we have the power to expel a member if

19      we deem it appropriate.  And, obviously, that's an

20      extreme power, but we do have the power.

21             I don't think that power exists -- well, in

22      local government, it just depends on the charter of

23      the city.  But each house of the legislature does

24      have that power.

25             SENATOR BORRELLO:  So since you have that







                                                             148
 1      power, would you consider that, basically, the teeth

 2      in your ethics commission, or at least some of it?

 3             CA SENATOR SCOTT WIENER:  I mean, that would

 4      be more than teeth.  It's pretty nuclear.  And, you

 5      know, obviously, under extreme circumstances, it can

 6      absolutely be warranted.

 7             But we also, you know, even issuing a letter

 8      of admonishment, or finding, if it's made public,

 9      which we have the power to make it public, can be

10      very powerful.  You know, obviously, no one wants

11      that kind of letter to be issued.

12             SENATOR BORRELLO:  Yeah.

13             CA SENATOR SCOTT WIENER:  But we can also

14      take away rights and privileges.  We could --

15      I think we can take away someone's office, or

16      someone's staff.

17             Ms. Peth will correct me if I'm wrong.

18             We can say, strip someone, or maybe the rules

19      committee, but the body has the power to strip

20      someone of their committee assignments, for example;

21      or perhaps to say, you can't introduce legislation

22      this year.

23             So we have pretty broad powers short of

24      expelling someone, to create strong incentives not

25      to mess up.







                                                             149
 1             SENATOR BORRELLO:  Great.  Thank you very

 2      much.

 3             Thank you.

 4             SENATOR BIAGGI:  Senator Palumbo.

 5             SENATOR PALUMBO:  Thank you, Madam Chair.

 6             Senator Wiener, nice to see you.

 7             CA SENATOR SCOTT WIENER:  You too.

 8             SENATOR PALUMBO:  By way of follow up:

 9             What are the, almost like, the practical

10      aspects of, for example, a very serious violation,

11      and now your committee determines that someone needs

12      to be removed?

13             Does that then go -- full Senate?

14             CA SENATOR SCOTT WIENER:  Yeah.  So any kind

15      of action, like, certainly, expelling a member,

16      removing someone from committees, I think, you know,

17      maybe saying a person can't introduce legislation,

18      I think that would -- we would refer that -- and

19      Ms. Peth will correct me if I'm wrong -- rules

20      committee.  And then it would probably go for --

21      floor for a full vote of the Senate.

22             Ms. Peth, am I being accurate there?

23             ERIN PETH, ESQ.:  Yes, that's correct.

24             CA SENATOR SCOTT WIENER:  Yeah.

25             SENATOR PALUMBO:  Okay.  Thank you.







                                                             150
 1             And is there any sort of an appellate process

 2      that they can -- you know, that it can be -- if the

 3      member objects, of course, to expulsion, they

 4      probably would, is there any further, if you want to

 5      call it "due process," or, that's it, they're done,

 6      pack it up?

 7             CA SENATOR SCOTT WIENER:  I don't think so.

 8             I think our constitution, and this is

 9      similar -- U.S. Constitution, that's full power in

10      each house of the legislature to determine the

11      qualifications, et cetera, of members.

12             And so that would be I think not -- not

13      justiciable in the courts.  I think the courts would

14      likely find that it's co-equal branch of government,

15      and there's no -- Senator, I will say that I found

16      this out on a personal level, when I was running for

17      reelection last year.

18             Initially, a former state senator had

19      announced he was going to -- in San Francisco was

20      going to run against me.

21             He was clearly and unequivocally termed

22      out -- had termed out 20 years before.  There was no

23      argument that he was not termed out.

24             And so I thought, okay, well, if he files to

25      run, we'll just, you know, make sure -- you know,







                                                             151
 1      we'll file an objection -- secretary of state, or do

 2      something, to keep him off the ballot.

 3             And multiple lawyers advised us, very smart

 4      lawyers, that a court was very unlikely to take

 5      action; that it was ministerial action to put him on

 6      the ballot.  And it would be up to the Senate, if he

 7      were to win, to decide not to seat him.

 8             So this is really all within the ambit of

 9      each house of the legislature.

10             I don't know what the New York constitution

11      says, but ours is very similar to the federal

12      Constitution.

13             SENATOR PALUMBO:  That's interesting.

14             And you said, so he's termed out.

15             You have term limits in the Senate in

16      California?

17             CA SENATOR SCOTT WIENER:  We have term limits

18      in the legislature.

19             It used to be, it was horrible, it was

20      six years in the Assembly, eight years in the

21      Senate.

22             And so in the Assembly, in particular, you

23      would have speakers who would either have had

24      six months under their belt, or were about to be

25      termed out.







                                                             152
 1             It was reformed about 12 years ago, that we

 2      can do 12 years either in one house or divided

 3      between two houses.

 4             So we have a 12-year term limit.

 5             So that's three 4-year terms in the Senate,

 6      or six 2-year terms in the Assembly.

 7             I don't recommend term limits.  So....

 8             SENATOR PALUMBO:  Well, thank you, Senator.

 9             And the use of the word "justiciable," it

10      sounds like you paid attention in law school.

11             I know Senator Hoylman is not here.  So, you

12      know, we're going to quiz him as well.

13             But, well done.

14             But thank you again.

15             Enjoy the holidays.

16             We appreciate you coming.

17             CA SENATOR SCOTT WIENER:  Thank you.  You

18      too.

19             SENATOR BIAGGI:  Thank you.

20             Senator Boyle.

21             SENATOR BOYLE:  Thank you, Madam Chair.

22             Thank you, Senator, for joining us.

23             And also kudos to California, if you said

24      that you didn't need the ethics committee because

25      there were no complaints for a few years.







                                                             153
 1             We would have it every few weeks, I think, so

 2      that would never work for us.

 3             Just to get back to your idea of expelling or

 4      reprimanding or punishing members of the

 5      legislature, can you or your counsel give any

 6      examples recently of anybody recently kicked out, or

 7      at least censured, or something, or...?

 8             CA SENATOR SCOTT WIENER:  Well, since I'm in

 9      my -- I'm about five years in, it hasn't happened.

10             There's was -- we had -- we had a period

11      about three years ago where we had some sexual

12      harassment problems in both houses.  One of my

13      colleagues, actually my seatmate, ultimately

14      resigned.  There were a few resignations in the

15      Assembly.  And I know there had been talk about

16      potential severe actions, up to and including

17      expulsion.  Nothing formal, it was just talk about

18      it.

19             But, ultimately, the members at issue

20      resigned, and so that became moot.

21             But as far as I can recall, there have not

22      been any censure or expulsion motions.

23             I know, in 2014, before I was there, we --

24      actually, it was two -- three senators resigned: two

25      for corruption, one because he was found not to live







                                                             154
 1      in his district.

 2             I actually think he was treated unfairly.  It

 3      was a bad situation.

 4             But the other two were straight up

 5      corruption, including one from San Francisco who was

 6      involved with like gun-running, and things like

 7      that.  It was really a bizarre situation.

 8             So they would have been expelled --

 9      I believe, would have been expelled; but ultimately

10      resigned, and went to prison --

11             SENATOR BOYLE:  Wow.

12             CA SENATOR SCOTT WIENER:  -- those two.

13             SENATOR BOYLE:  Well, very good.

14             Thank you.

15             CA SENATOR SCOTT WIENER:  The third one was

16      ultimately, down the road, I think, pardoned by

17      [indiscernible].

18             SENATOR BOYLE:  Well, we have similar

19      problems in New York, but mostly in the governor's

20      mansion as opposed to the legislature.  So....

21             But thank you for joining us, Senator.

22             SENATOR BIAGGI:  Thank you so much.

23             I just have a few questions, just to kind of

24      bow -- put a bow on today's questioning with you,

25      because you've answered a lot of them.







                                                             155
 1             And I'm going to ask you the question that

 2      I asked also the members of the Senate from Alaska

 3      and Rhode Island when we had our last hearing.

 4             And the reason I'm going to ask this question

 5      is because of this very undercurrent in New York.

 6             New York ranks 31st when it comes to

 7      ethics, and just overall corruption and transparency

 8      efforts; whereas California ranks second.

 9             So, really, hats off to all of you for that.

10             And so, from your vantage point in

11      California, what is your perception of how New York

12      handles ethics?

13             And please be as honest as possible, and the

14      reason I say that, it's not really not a joke, even

15      though it's almost laughable just how absurd it is.

16             But we want to be able to understand how the

17      rest of the country and the world views us, and so

18      it's important that you be as honest as you

19      absolutely can be with us.  No offense will be

20      taken.

21             CA SENATOR SCOTT WIENER:  So I grew up in

22      New Jersey, in the southern part of the state.  And

23      I know New Jersey has a certain reputation.  I don't

24      know where New Jersey currently ranks on that list.

25             But -- so -- no, I don't -- and I don't







                                                             156
 1      perceive New York to be in that category.

 2             I actually, you know, my perception, which is

 3      really based on the news -- obviously, I'm not

 4      personally involved -- is, you know, I saw,

 5      obviously, everything that happened with your former

 6      governor, and not just the issues that caused him to

 7      resign, but just sort of the way he seemed to move

 8      in the world, which is -- would not make me happy if

 9      our governor did that.

10             SENATOR BIAGGI:  Yep.

11             CA SENATOR SCOTT WIENER:  But -- and then the

12      speaker of the Assembly, you know, I saw that.

13             But I never attributed that to --

14      I couldn't -- I had no way of knowing if that was a

15      broader issue, or it was just like a few -- you

16      know, there's always going to be people who act in

17      inappropriate ways even in the best of systems.

18             And, ultimately, the system caught up with

19      them, and they left.

20             So I really don't have a perception one way

21      or the other.

22             I would say if I did, but I don't.

23             SENATOR BIAGGI:  I appreciate that.  That

24      means a great deal.

25             Okay.  So just two more questions.







                                                             157
 1             So your committee -- you mentioned this, that

 2      your committee is tasked with developing the

 3      standards of conduct for all the senators, Senate

 4      officers, and also employees.

 5             Can you just share a little bit more about

 6      that work, and just how often your committee revises

 7      the standards, and do you find that this process is

 8      effective?

 9             We have some role in some of those kinds of

10      issues.  But a lot of what we are dealing with, when

11      it comes to ethics in New York, specifically with

12      members and legislative officers, is from a section

13      of our law and statute, Section 74 of the Public

14      Officers Law.

15             So this is a little bit different.

16             So I'm just wondering about the process.

17             CA SENATOR SCOTT WIENER:  Yeah, so we --

18      these standards were adopted, I think it was in

19      2014, or thereabouts, and so they're still pretty

20      fresh.  They're not like, you know, 50-year-old

21      standards.

22             I -- we -- I know that, in going through some

23      recent processes in the committee, we noticed that

24      there was some language that needed to be tightened

25      up a little bit.







                                                             158
 1             And so I know we were looking at potentially

 2      just making some things clearer, because, you know,

 3      until you start implementing standards, sometimes

 4      you don't know if they have been drafted, you know,

 5      as tightly as they could be.

 6             I don't think we're planning any significant

 7      or substantive changes at the moment.

 8             Again, these are only seven years old and

 9      they seem to be working well.

10             But I think we -- you know, I mean, if we

11      ever see a gap, or something, that, you know, we

12      didn't anticipate, we wouldn't hesitate to take a

13      look and to propose modifications.

14             SENATOR BIAGGI:  Would you be able to modify

15      them -- well, that's actually much better.

16             Would you be able to modify them at any time,

17      or does it have to be a certain time of year?

18             CA SENATOR SCOTT WIENER:  No, it's at any

19      time the committee could propose a modification to

20      the full Senate, and then it would just be voted on

21      by the full Senate.

22             SENATOR BIAGGI:  Okay.  That makes sense.

23             And then, in terms of the other house,

24      obviously there's the Senate, and the --

25             Is it called "the House" in California, or







                                                             159
 1      the Assembly?

 2             CA SENATOR SCOTT WIENER:  It's Assembly.

 3             SENATOR BIAGGI:  It's the Assembly.  Okay.

 4             -- so in the Assembly, do you have standards

 5      that are mirroring each other?

 6             And the reason -- let me just share the

 7      reason why I asked this question.

 8             Because, obviously, these are two separate

 9      houses with two different types of bodies, and so

10      we're very much aware of that.

11             But in New York, our rules are -- for --

12      certain rules are different.  And so what that leads

13      to in New York is a little bit of confusion as to,

14      if you're a staff member, as opposed, you know, in

15      one house versus the other house, it might be a

16      different process.  Where do I go?  Who do I talk

17      to?

18             It becomes a little confusing.

19             So, just, can you walk us through that; is

20      there a similarity?

21             CA SENATOR SCOTT WIENER:  So we do -- we do

22      have, for example, we have joint rules of the

23      legislature, which mostly govern the legislative

24      process and calendar so the two houses are in sync.

25             And then each house has its own rules, and







                                                             160
 1      the Assembly have their own standards of conduct.

 2             One area where we have worked together is

 3      around workplace conduct, and, like, this was

 4      created -- a workplace conduct unit was created

 5      after the sexual harassment situations that

 6      I mentioned a few years ago.  So in that area we

 7      have worked together.

 8             But perhaps Ms. Peth can comment further on

 9      those issues.

10             ERIN PETH, ESQ.:  Yes, so the Assembly does

11      have their own ethics and their own standing rules,

12      and so they're pretty similar to our standards of

13      conduct in the Senate.

14             But we have, actually, as we talked about

15      today, pulled those standards of conduct out in a

16      separate sort of stand-alone document.

17             But I would say, overall, the rules are

18      pretty similar.

19             But I understand what you are saying about

20      confusion.  You know, we do have staff members, I'm

21      sure you do in New York also, that switch between

22      the houses.

23             So I think keeping the rules as consistent as

24      possible is helpful.

25             We also have many Assembly members who then







                                                             161
 1      are ultimately elected to the Senate.

 2             So we do try to work together, to make sure

 3      we're staying consistent.

 4             And in my capacity as chief counsel -- ethics

 5      committee, there's a staff member on the Assembly

 6      side who has the same -- basically, the same

 7      position.  I work really closely with him as well,

 8      so that we make sure we're staying consistent in our

 9      advice, so that we, you know, sort of minimize, as

10      you said, confusion by the members and staff.

11             We want to make sure the houses sort of have

12      the same advice and counsel coming out as well.

13             SENATOR BIAGGI:  [Simultaneous talking.]

14             Go ahead.

15             CA SENATOR SCOTT WIENER:  One thing I will

16      just add, that is probably a California-specific

17      issue that will become, hopefully, less of an issue,

18      is that, historically, before the current iteration

19      of term limits, so, preterm limits, and then when we

20      had separate term limits for each house, the

21      senators were overwhelmingly former Assembly

22      members; served in the Assembly, and then moved --

23      got elected to the Senate.

24             And so, as a result, the Assembly does a lot

25      of initial training of new members, in terms of all







                                                             162
 1      the way the house works, the, you know, ethics,

 2      everything else, that you need to know as a new

 3      member of the legislature, and like pitfalls, and,

 4      you know, don't talk about -- you know, legislation

 5      when you're having a fundraiser, or all these things

 6      that someone can easily, if they don't have strong

 7      training, could have a lapse.

 8             And so because the Senate historically was

 9      overwhelmingly former Assembly members, the Senate

10      had less training because the members were already,

11      you know, experienced Assembly members.

12             With the change -- 12-year term limit, where

13      you can be in one house, we have more and more

14      senators, like myself, who never served in the

15      Assembly, who went right from local government, or

16      from no office at all, to being a senator.

17             And so we've sort of recognized recently that

18      we're going to have to -- we need to have more

19      training because we have more and more senators who

20      have no previous legislative experience.

21             And so we're going to be making -- our pro

22      tem has indicated that we're going to ramp that up.

23             SENATOR BIAGGI:  That sounds, actually, quite

24      important, and I agree with that.

25             And I think when it comes to training,







                                                             163
 1      I think as much as you can possibly get to be very

 2      clear about the boundaries is essential.

 3             And so -- and we have the same kind of

 4      dynamic in New York, with a lot of people who have

 5      not served in government, who are now in government,

 6      and really just need maybe a little more help.

 7             Just two more questions, but going back --

 8      workplace conduct unit that you said that you

 9      created, what is the makeup of that?

10             And, also, did you have to create it by

11      legislation? by rule? by regulation?

12             CA SENATOR SCOTT WIENER:  That was created --

13      well, we did a few things.

14             The legislature used to be exempt from

15      retaliation claims.

16             We removed -- we legislated to -- we

17      legislated the elimination of that exemption.

18             In addition, I believe it was by rule that we

19      created the workplace conduct unit.

20             Ms. Peth is nodding her head.

21             I'm trying to dredge my memory back.

22             That unit is not comprised of members.  That

23      is -- there is -- it's made up of staff, and there's

24      an outside person.  But Ms. Peth perhaps can

25      describe it.







                                                             164
 1             ERIN PETH, ESQ.:  Yeah, I'm happy to.

 2             CA SENATOR SCOTT WIENER:  We were trying to

 3      create a safe place for people, you know,

 4      particularly in the sexual harassment context, to be

 5      able to come forward and make a complaint.

 6             SENATOR BIAGGI:  That's great.

 7             ERIN PETH, ESQ.:  Yes, and so kind of echoing

 8      what we said earlier, there was a lot of -- during

 9      sort of the "Me Too" movement a few years ago, there

10      was a lot of criticism that the Senate and the

11      Assembly were handling those kinds of complaints and

12      allegations in different ways.

13             And so the houses worked together to create

14      that workplace conduct unit.

15             It's actually located in the office of the

16      legislative counsel, which is a -- basically, the

17      legislature's lawyers.  So they created a separate

18      unit within that office of legislative counsel, and

19      they staff it with lawyers and investigators who

20      basically do the preliminary, you know, review and

21      the investigations.  And then it goes to, I believe,

22      and I would have to -- I -- we can provide this to

23      you, but I believe that there -- the California

24      Supreme Court Chief Justice appoints people to then

25      review -- review the reports that are produced by







                                                             165
 1      the investigators and the lawyers.  And then it goes

 2      back -- House to actually figure out, you know

 3      whether -- you know, if the allegations are proven

 4      true, what is going to be the results?

 5             You know, so that goes back to what

 6      Senator Wiener was saying earlier, in terms of the

 7      House still having control over obviously employees,

 8      but also members, in terms of what type of

 9      discipline would be appropriate.

10             But I'm happy to follow up with more detail

11      on how those appointments happen, if that's helpful.

12             SENATOR BIAGGI:  I would love that, actually,

13      because it's an interesting, and I think --

14      "interesting" is not the right adjective.

15             It's a smart way to handle those kinds of

16      issues.

17             And the fact that it goes -- chief judge is

18      actually another check on what is happening

19      internally, because I think a lot of the criticism

20      in New York as well, is that, when things are

21      handled internally, then how could you be impartial

22      if you have to make a decision about a colleague or

23      somebody else.  But having that extra check is

24      important, and then bringing it back.

25             So I know it's a challenging way to set it







                                                             166
 1      up, but I would like to actually have more

 2      information about that.  That would be really,

 3      really great.

 4             This last question -- and, frankly, if you

 5      can't answer it, that's totally fine -- but this is

 6      something I think that is -- it's important to me

 7      for the reason of just coming out of a cycle that we

 8      repeat and repeat and repeat, because of elections,

 9      because of dynamics.  And it's, basically -- and

10      it's more of like an ethical question as opposed to

11      legislative ethics.

12             And so I know, Senator Wiener, you had

13      mentioned, just, you want to be very focused on

14      those questions.  And so, again, it's okay if you

15      cannot answer this.

16             But, in the legislature, in the Senate, are

17      the legislative budgets equal across both houses?

18             Meaning, if you have -- obviously, you have

19      Republican colleagues, and so they get a budget to

20      set up an office, they get a budget to set up staff.

21      And then, of course, you know, as -- you know, the

22      other party, the Democratic party, gets the same

23      kind of thing.

24             Do both parties, no matter whether you're in

25      the majority or the minority, get the same budget?







                                                             167
 1             The reason I say this is because there is

 2      just a sense of fairness, I think, that goes into

 3      this, that it kind of -- it goes back and forth, at

 4      least in New York -- right? -- the majority has a

 5      larger budget, presumably because there's more

 6      people and you need more staff, of course, to run

 7      the Senate, which makes sense.

 8             But when it comes to the individual members,

 9      I'm just wondering what California does, and if you

10      have an imbalance or the same.

11             CA SENATOR SCOTT WIENER:  The two houses are

12      very different.

13             The Assembly, each member gets a pot of

14      money, and so they can hire fewer staff at higher

15      salaries, or more staff at lower salaries, for

16      example.  And it's up -- speaker.

17             So even among Democrats, like different

18      people may get different pots of money.

19             The Senate is much more regimented.

20             So when I came in, it was, like, if you were

21      a senator that represents more than one county, you

22      get 12 staffers, with very regimented slots of what

23      those are, ranging from chief of staff, down to like

24      a legislative aide or an administrative assistant.

25             And if you represent one county, you got 10.







                                                             168
 1      Over time, you know, you might get different

 2      staffers for different reasons.

 3             But I think it's a little more regimented in

 4      the Senate.

 5             I believe Democrats and Republicans get the

 6      same staffing in the Senate, I believe.

 7             You know, their -- yeah -- I mean -- and, of

 8      course, our budget, in general, is bigger because

 9      we're a much bigger caucus.

10             But the Republicans also have, you know --

11      you know, minority staff on each committee, and --

12      or they may have one consultant who handles multiple

13      committees.

14             You know, we have, at this point, a declining

15      number of Republicans.  So some of my Republican

16      colleagues have complained to me that they serve on

17      so many committees, because they're stretched to

18      different committee.

19             SENATOR BIAGGI:  Sure.

20             CA SENATOR SCOTT WIENER:  But, yeah.

21             SENATOR BIAGGI:  Okay.  That's very helpful.

22             Yes, I know it used to be us.

23             We were -- oh, yes, yes.  Please, yes,

24      Senator Boyle.

25             And thank you for answering that question.







                                                             169
 1             CA SENATOR SCOTT WIENER:  And I do have to,

 2      unfortunately, run in a minute.

 3             SENATOR BIAGGI:  I know, two minutes.

 4             CA SENATOR SCOTT WIENER:  But I can do one

 5      more question.

 6             SENATOR BOYLE:  Very quickly, Senator; and

 7      thank you very much.

 8             And thank you, Madam Chair, for bringing that

 9      up.

10             This is an issue, before I was elected to the

11      state legislature many years ago, I served on

12      Capitol Hill as a congressional staffer for

13      five years.  And whether you were the most senior

14      Republican or Democrat, or minor, everyone had the

15      exact same amount for staff.  Central staff was

16      different, obviously; but for the different offices

17      in Congress.

18             And I believe that we had a court case in

19      New York State.  I believe our colleague,

20      Senator Krueger, when she was in the minority,

21      was -- with our late colleagues, Tom Kerwin, the

22      Assemblyman, to try and get equal staffing at equal

23      amounts.

24             SENATOR KRUEGER:  We sued.

25             SENATOR BOYLE:  You sued/they sued.  They







                                                             170
 1      lost.

 2             And I believe -- I believe, in some of the

 3      testimony, there was to say that, Well, if the

 4      speaker said that a Republican had one dollar for

 5      their staff, would that be acceptable?

 6             The judge said, Yes, because, you know, it's

 7      a different thing.  We're not getting involved with

 8      [indiscernible] a judicial thing.

 9             But I do hope the state legislature looks at

10      that, for fairness and equity.

11             And I congratulate you for mentioning that.

12             SENATOR BIAGGI:  Thank you very much.

13             And, Senator Wiener, thank you so much for

14      spending time with us.

15             And, Erin, the same for you; we appreciate

16      it.

17             And I really do look forward to working with

18      both of you, hopefully, in the future, not just

19      ethics, but, of course, on other things.

20             So thank you very much for taking the time.

21             CA SENATOR SCOTT WIENER:  Yes.

22             And congratulations to New York for, as you

23      said, lapping us on safe consumption sites.

24             We're jealous in San Francisco because we

25      needed to do it for so long.







                                                             171
 1             But you all beat us to the punch.

 2             Congratulations.

 3             SENATOR BIAGGI:  Thanks very much.

 4             Have a good rest of your day, and happy

 5      holidays.

 6             CA SENATOR SCOTT WIENER:  Happy holidays.

 7             ERIN PETH, ESQ.:  Thank you.

 8             SENATOR BIAGGI:  Thank you.

 9             Okay.  So we're just going to take a

10      10-minute break before our final panel of the day.

11             We actually added on someone from the

12      judicial conduct panel -- commission, rather.

13      Excuse me.

14             Yes, just 10 minutes, and we'll come back.

15             So, 1:10, we'll return.

16                (A recess was taken.)

17                (The hearing resumes.)

18             SENATOR BIAGGI:  Okay, wonderful.  Welcome

19      back, everyone.

20             We are on our final panel of the day, and

21      we're very, very grateful to be joined by

22      Robert Tembeckjian, who is from the Judicial Conduct

23      Commission, to hear about what the commission does,

24      of course, and, also, some of the ways in which it

25      works.







                                                             172
 1             And we're very grateful that you're here

 2      today, of course.

 3             I'm a member of the Judiciary Committee, but

 4      we also have with us, of course, the chair of the

 5      Judiciary Committee here too, Senator Hoylman.

 6             And so, with that, we give you the floor to

 7      please share your testimony.

 8             ROBERT H. TEMBECKJIAN:  Thank you.

 9      I appreciate that very much.

10             I wanted to just make a couple of points,

11      before we get to questions, on the significance of

12      the independence -- the structural independence of

13      any new commission or ethics entity that you

14      propose, and some of the other considerations that

15      should go into the structure of a robust ethics

16      enforcement entity.

17             And I do that from the experience of having

18      been an ethics enforcement officer for the judiciary

19      for more than 40 years, and I've been the

20      administrator of the commission since 2003.

21             Structural independence is critical.

22             We are created in the state constitution, and

23      the commission itself is a body of 11 members, 4 of

24      whom must be judges, 5 of whom are lawyers, 2 of

25      whom are laypeople.  And that balance in membership







                                                             173
 1      is very significant.

 2             The judiciary does not control the

 3      investigation and enforcement of discipline against

 4      judges, but it does have a participating role and

 5      voice, so that decisions are not made without the

 6      input of people who understand something about what

 7      judges do and what they experience in the

 8      day-to-day.

 9             At the same time, it is, I think, especially

10      important that there be non-lawyer members, because

11      so much of what government does, especially in the

12      field of ethics enforcement, is aimed at bolstering

13      public confidence and the integrity of our form of

14      government.

15             The public has a way of viewing judicial

16      misconduct differently and from a different

17      perspective than lawyers and judges do.

18             And it might not surprise you that judges and

19      lawyers are among the least likely to make

20      complaints about judges, because it's their world

21      and its their livelihood.

22             Bringing laypeople -- conversation is very

23      important perspective to keep mindful of as you're

24      crafting the way forward in New York for ethics

25      enforcement in the future.







                                                             174
 1             Within the structure, not only because we're

 2      in the constitution, but the structure of the

 3      commission itself, means that no one appointing

 4      authority controls the body.

 5             There are six different appointing

 6      authorities.

 7             The governor appoints four members, the

 8      chief judge of the state appoints three, and the

 9      four leaders of the legislature each appoints one.

10      And none of them designates the chair or chief

11      executive officer.

12             The commission itself elects its own chair

13      for a two-year term.  And then they retain an

14      administrator who serves as the chief executive

15      officer, and, under statute, is responsible for the

16      day-to-day operation of the agency.

17             And that is extremely important because, in

18      other states, where the chief judge, for example,

19      chooses the chief executive officer of judicial

20      enforcement, if the Judicial Conduct Commission is

21      upsetting the court system or the chief judge, let's

22      say, by being too effective or too aggressive or too

23      robust, they serve at the pleasure of the chief and

24      they can be dismissed.

25             As we've seen in other context, if you are







                                                             175
 1      running afoul of the governor, and the governor

 2      appoints you as either the chair or the chief

 3      executive officer, the governor can make a change,

 4      and effective enforcement, essentially, is going to

 5      be shadowed by the fear of losing your job for doing

 6      it effectively.

 7             So I would urge that any legislation that you

 8      craft or constitutional amendment take care for

 9      that.

10             And, secondly, most significantly, if --

11      if -- even the most perfect constitutional or

12      legislative structure is going to be ineffective if

13      it's not well funded; if it doesn't have the

14      resources to do its job.  And if the resources are

15      going to be controlled by some entity that has a

16      stake in the game, that's going to present problems.

17             As my friends, Senator Krueger and

18      Senator Hoylman, well know, for the last 10 years,

19      the division of budget, in its submission of the

20      executive budget -- legislature, which includes my

21      commission's budget, has, essentially, frozen us

22      out.  They keep us flat year after year after year.

23             The decision was made some time ago for our

24      budget to be submitted separate from the judiciary

25      so that they couldn't control our operations by







                                                             176
 1      controlling the purse strings.

 2             But if you don't have a governor who is -- to

 3      the subject, and a division of budget that,

 4      essentially, keeps you flat because they consider

 5      you, despite the constitutional separation, as an

 6      executive branch operation, which we are not, it

 7      forces me to come -- legislature year after year to

 8      ask for the funding that we need.

 9             And I've been very fortunate with this

10      representation, that the legislature has been

11      responsive.  But it shouldn't have to come to that,

12      really.

13             I'd like to see a system, and I think this is

14      reflected in the constitutional amendment that

15      Senator Krueger has proposed, by which the ethics

16      enforcement entity submits its budget requests to

17      you directly, without the filter of the governor.

18      And then you decide, as the legislative body and the

19      representative of all of the people, what that

20      effective or appropriate level of funding should be.

21             I'd like to see that for our own commission

22      too.

23             And I must say that, in recent weeks, I have

24      suggested that -- staff of the new governor.  And,

25      lo and behold, unlike the previous 10 years, they







                                                             177
 1      actually seem to be attentive -- subject.

 2             And I have some hope that, this year, when

 3      the executive budget comes out, it reflects this

 4      respect for the independence of the commission and

 5      the constitutional independence of this body, and

 6      the importance of ethics enforcement.

 7             I certainly hope that that's the case.

 8             Two more points that I think are really

 9      significant.

10             One is transparency.

11             Whatever the structure is, there must be,

12      I think, a public window into what the work that the

13      ethics commission or body is doing.

14             If the public can't see that ethics are being

15      enforced, they're not going to believe that it's

16      happening, even if, at the end of a long inquiry,

17      there is some discipline imposed.

18             Under the law in New York, which is in the

19      minority of states, judicial discipline only becomes

20      public at the end of the process.

21             In most states, once the body formally

22      charges a judge with misconduct, the matter becomes

23      public, in the same way that a grand jury

24      investigation is private, confidential, but once

25      charges are preferred or indictment is returned, the







                                                             178
 1      matter becomes public, and so forth.

 2             There have been over the years, you know,

 3      some discussion about changing that.

 4             Even without that, we contribute --

 5      transparency of our operation by putting on our

 6      website virtually everything.

 7             We have disciplined 903 judges in the last

 8      40 years.  Every single one of those decisions is on

 9      our website.  The records on which those decisions

10      are made are available -- public.

11             We have all of our rules, internal and

12      external, published on the website.

13             All of our press releases are on there.  Of

14      course, those are public documents anyway.

15             We have a code of ethics that we've adopted

16      in addition to what's in the Public Officers Law.

17      That's available on our website.

18             Judges can see/the affected body can see,

19      what it is we do, how we do it.  And lawyers that

20      represent them when they do get into trouble, will

21      appreciate and understand how the commission works,

22      because our website is so full.  I mean, I think

23      it's fair to say that it is probably the most

24      comprehensive website of its type around the

25      country, in terms of judicial disciplinary







                                                             179
 1      enforcement, and probably, compared to other ethics

 2      entities in New York State, it's a cut above.

 3             And, lastly, and most significantly, is to

 4      build in, I think, a regular, required "training and

 5      education" component.

 6             Judges are required to attend education and

 7      training programs after they are elected or

 8      appointed to new office or elevated from lower court

 9      to higher court.

10             The Office of Court Administration makes

11      education training programs available throughout the

12      year for all levels of the court system, including

13      all of the different categories of judge: county

14      court judge, Supreme Court, and so forth.

15             The Judicial Institute, which is designed to

16      put these programs on, makes it a point to include

17      at least two ethics components to every training of

18      newly elected or newly appointed judges, one of

19      which is presented by representatives of the

20      Judicial Conduct Commission.

21             We tell judges not only how we operate and

22      how we're structured, but how to avoid getting into

23      trouble, and avoid having to see me on any occasion,

24      other than the training and education that welcomes

25      them -- bench.







                                                             180
 1             I know there are regular training and

 2      education programs and seminars that the legislature

 3      runs.

 4             I think the executive branch really needs to

 5      do the same.

 6             It's not just being able to go online and

 7      sort of check off the box of an online program; but

 8      to actually have structured programs that deal with

 9      the specific ethical areas that legislators or

10      executive branch employees, as we do for the

11      judiciary, are likely to get in trouble for, so that

12      they can avoid them.

13             And I think it's one of the most effective

14      roles that we play.

15             I would rather scare them straight to stay

16      away from me during their tenure on the bench, than

17      to wait until they get into trouble before they

18      first come to appreciate exactly what it is that we

19      do, and the powerful disciplines that we can impose.

20             As you know, the commission can impose public

21      admonition, public censure, removal from office for

22      egregious misbehavior, retirement for medical or

23      physical -- mental or physical disability.

24             We also can privately caution for minor

25      violations, and that's an important factor to build







                                                             181
 1      in.  There are -- not every violation of an ethics

 2      code requires public discipline in the opprobrium of

 3      the public.

 4             There is a place for private warnings to,

 5      "Don't do it again.  Be a better public servant."

 6             We don't have the power to suspend, and

 7      that's something that we've also discussed at

 8      various times with the legislature.

 9             So having an appropriate range of disciplines

10      that can be imposed is also, I think, very, very

11      significant.

12             And I'm aware, from having observed your

13      first hearing in Albany, and watching a little bit

14      on video today, that, certainly, this group of

15      senators certainly seems to be aware of and

16      sensitive to these general subjects.

17             You can tell from the questions that you have

18      been asking, and the areas that you want to cover,

19      with the other witnesses.

20             I hope you are able to persuade the balance

21      of your colleagues to be as attentive to these

22      issues as certainly all of you have been.

23             And I appreciate your having me here, to be

24      able to share some of my experiences, and,

25      certainly, to answer whatever questions you might







                                                             182
 1      have.

 2             SENATOR BIAGGI:  Thank you so much.

 3             ROBERT H. TEMBECKJIAN:  And maybe,

 4      Senator Biaggi, to show that it's nothing to be

 5      afraid of for other entities to come before this

 6      body and speak to them.

 7             SENATOR BIAGGI:  That's right.  That is

 8      exactly right.

 9             If that could the theme of this hearing,

10      I would put it right at the top.

11             So, thank you for saying that.

12             We'll start with Senator Krueger, and thank

13      you for your testimony.

14             ROBERT H. TEMBECKJIAN:  Thank you.

15             SENATOR KRUEGER:  So thank you, Robert, for

16      actually volunteering to come, as opposed to being

17      worried about coming to talk to us today.

18             ROBERT H. TEMBECKJIAN:  Well, I've had

19      experience in speaking before you, and I know it's

20      nothing to be afraid of.

21             It's actually what we call "good government."

22             SENATOR KRUEGER:  That's right, we do call it

23      "good government."

24             And I always -- we've gotten to know each

25      other over the years because of your budgets







                                                             183
 1      [indiscernible] with the previous governor.

 2             But, also, I don't know if you remember, but

 3      the very first time I think I talked to was because

 4      the building I lived in was in a legal dispute

 5      with -- between tenants, and a judge, in open court,

 6      called out to people, "How many people here haven't

 7      gotten a raise in 14 years?  I haven't."

 8             "Senator Krueger?"

 9             I said, "I haven't either."

10             Because that was true.

11             And then continued on about, Why would you go

12      to work if you don't get paid?

13             ROBERT H. TEMBECKJIAN:  Right.

14             SENATOR KRUEGER:  And so then I asked her in

15      open court, "Are you going to recuse yourself now

16      that you've done this?"

17             She said, "Of course not."

18             And then I didn't know what to do with that,

19      because I'm not a lawyer.  I just knew the words

20      "recuse yourself."

21             ROBERT H. TEMBECKJIAN:  Well, you might

22      remember that we publicly censured a judge from

23      Western New York, who had urged other judges not to

24      preside over cases in which the lawyers were members

25      of the legislature; effectively, trying to freeze







                                                             184
 1      the legislature out of court until they mandated a

 2      pay raise for judges.

 3             And he eventually apologized, and

 4      acknowledged that what he did was improper.  But he

 5      was, nevertheless, publicly censored for it, in part

 6      because we have, I think, a robust enforcement

 7      mechanism for the judiciary, that we could certainly

 8      use for the executive, and perhaps the legislature

 9      too.

10             SENATOR KRUEGER:  Right.

11             So that was a real lesson for me, because

12      then I -- again, I wasn't the lawyer.  I was a --

13      just somebody in the case.

14             And I asked my lawyer, "Will you file with

15      the commission?"

16             And the lawyer didn't want to, because

17      lawyers don't necessarily want to be seen as

18      troublemakers with judges, which is, I think, one

19      issue.

20             But then I learned what the commission did,

21      and how valuable it is.

22             So it seems to me, it's critically important,

23      and it's such a good model, for looking at how we

24      deal with other ethics issues, because of exactly

25      what you just said to us.







                                                             185
 1             You know, and we've talked about, you know, a

 2      JCOPE proposal, or alternative to JCOPE proposal,

 3      and the importance of independence, the importance

 4      of transparency, the importance of it being an

 5      educational and a training function as well, to

 6      prevent people from making mistakes and crossing

 7      lines, and just what you just described.

 8             I've always found it fascinating, we elect

 9      people judges, and then we just assume they would

10      know what to do.

11             How ridiculous.  Right?

12             They knew how to run for judge.

13             ROBERT H. TEMBECKJIAN:  Yes, they did.

14             SENATOR KRUEGER:  But it doesn't mean they

15      know how to be a judge.

16             ROBERT H. TEMBECKJIAN:  Right.

17             SENATOR KRUEGER:  And, so, all these

18      functions are so important.

19             So I just think it's very valuable, as the

20      committee continues to look at what we're trying do,

21      that we look at the language in your statute that

22      created you, and take some of the really important

23      models there, including your point that you have

24      your own code of conduct that you built in.

25             ROBERT H. TEMBECKJIAN:  Yes.







                                                             186
 1             For our commission members, that's right.

 2             SENATOR KRUEGER:  Okay.

 3             And so judges can actually be found to have

 4      failed to sort of stand up under your code of

 5      conduct.

 6             ROBERT H. TEMBECKJIAN:  Oh, well, there is a

 7      code of judicial conduct which is mandatory and must

 8      be observed by all judges.  That's based on the

 9      American Bar Association model, code of judicial

10      conduct.  And it's that code that we impose on

11      judges.

12             But for our own commission members, we have

13      adopted an additional code of conduct that's more

14      stringent than what is in the Public Officers Law,

15      in part because we want to impress on the public

16      that this is a body that is [sic] above reproach.

17             That it's not satisfied only to adhere to the

18      more generalized ethics mandates of the Public

19      Officers Law, but recognizing that there are

20      peculiar responsibilities to a judicial enforcement

21      entity that require language that wasn't in the

22      Public Officers Law.

23             And so we adopted that for our own members,

24      and it's another way, I think, of impressing on the

25      judiciary and the public that we take our







                                                             187
 1      responsibilities seriously enough to impose

 2      additional burdens on ourselves.

 3             And this is on a commission membership, by

 4      the way.  As you know, the commission members all

 5      serve without compensation.  It's volunteer work.

 6      But they're all, you know, highly civically-minded,

 7      and understand the importance of what it is that

 8      they're doing.

 9             SENATOR KRUEGER:  You know, I just want to

10      say, I think that is such a great model for us to

11      think about, even just for elected officials, and

12      for people who work for the executive, a code of

13      conduct.

14             I often explain to people that I actually

15      think elected officials should be held to a higher

16      standard than the rest of the people of

17      New York State, because no one put a gun in our

18      heads and said, You have to serve as elected

19      officials.

20             We went out there and asked people to vote

21      for us, to give us the power to decide the laws

22      they're going to live under.

23             So it's always seemed to me that that then

24      obligates us to a higher standard of following the

25      laws because we're writing the laws.







                                                             188
 1             And so I think the concept of a -- and we all

 2      know, we take an oath of office, and it's one

 3      sentence, about upholding the Constitution.

 4             And I'm not going to test anyone, but would

 5      I flunk if someone gave me a constitutional test to

 6      find out how much of it I knew that I was trying to

 7      uphold.

 8             ROBERT H. TEMBECKJIAN:  Right?

 9             SENATOR KRUEGER:  Right?

10             So, you know, actually having a code that we

11      all have to actually read and think about, and sign

12      off on, I think also would be a really valuable idea

13      for us.

14             So I appreciate that as well.

15             ROBERT H. TEMBECKJIAN:  And we certainly feel

16      the same way about the judiciary.

17             In fact, the court of appeals, in upholding

18      some of our removal decisions, has commented

19      specifically on the importance of holding judges to

20      a higher standard than that of the marketplace,

21      certainly, because if the public is going have

22      confidence in our system of government, it has to

23      believe that the people who arbit our disputes are

24      and appear to be fair and impartial and independent,

25      and also accountable for when they transgress.







                                                             189
 1             And if that doesn't happen, then our entire

 2      social structure is going to collapse, and the way

 3      we settle our disputes will move from the courtrooms

 4      and civilized discourse into the streets.

 5             And it's one of the things that distinguishes

 6      the American form of government from so many others,

 7      it's that -- is that we have structures and forms,

 8      we have purposely, you know, divided government, so

 9      that there are separate and independent branches.

10             And although not everybody necessarily

11      respects and appreciates that, you know, those of us

12      on the enforcement end at least try to live up to

13      that high standard.

14             And I think, in my experience, although, as

15      I've said, you know, we've disciplined over

16      900 judges in 40 years, which is more than 20 a

17      year, the vast majority of judges in New York State,

18      3400 of them, are capable, honorable, honest,

19      hard-working people who try to get it right.

20             And the public needs to know that, for those

21      relative few who get it wrong, there is going to be

22      recourse.  And that's what we try to accomplish.

23             And I think, as I heard from some of your

24      witnesses earlier this morning, they seem to think

25      that we do a fairly good job of it.







                                                             190
 1             SENATOR KRUEGER:  And just one more question,

 2      if I might, because you listened to the testimony of

 3      other people, some of the discussion.

 4             So are there lessons from your work, with

 5      having your own inspectors doing these kinds of

 6      cases, when we're looking at trying to make

 7      improvements in our model of inspector general?

 8             I mean, is there just sort of protocols of

 9      how you handle these investigations, that you feel,

10      like, you know, you figured it out over 40 years,

11      not you personally, but the commission, and that

12      perhaps we're not giving the right instructions to

13      our inspector general?

14             ROBERT H. TEMBECKJIAN:  Well, one of the

15      distinctions between the inspector general model and

16      the commission model is that, while the inspector

17      general can decide what to investigate and what not,

18      as the relative equivalent of the judiciary, I don't

19      have that authority.

20             I have to make a recommendation to an

21      11-member body, which means that I need to persuade

22      them that there is basis here to investigate a

23      complaint.  But it also means that I can't tank one;

24      that I can't -- you know, I can't sort of look the

25      other way perhaps because the complaint is against







                                                             191
 1      my employer, or the person to whom I'm supposed to

 2      report.

 3             A system that is designed that way, without

 4      accountability, without some check and balance, is

 5      one that's likely to fail, or likely to pick on what

 6      we call "low-hanging fruit," the easy cases.

 7             But when the complaints are against those who

 8      are in authority, they're more likely to turn the

 9      other way, particularly if they serve at the

10      pleasure of the person against whom the complaint

11      might be made.

12             Even if the inspector general -- and

13      I have -- and I make no comment on the integrity of

14      the people who have held this position.  I happen to

15      know some from the past and I have the highest

16      regard for them.

17             One in the past that I know, investigated a

18      complaint against the governor that appointed her.

19      That was some years ago.

20             But even if every decision of an inspector

21      general is honest, and would stand up to public

22      scrutiny, if the structure is as it currently is,

23      the public is not going to believe that a complaint

24      against the governor, or the secretary to the

25      governor, or anyone on the governor's staff, or







                                                             192
 1      anyone close to the governor, or a commissioner that

 2      the governor appointed, is going to get robust

 3      scrutiny.

 4             The only way that you can convince the public

 5      that high officials are being held accountable is to

 6      hold them accountable, and to show that you've done

 7      it.

 8             And when was the last time that a

 9      commissioner appointed by a governor, or a governor,

10      or someone on the governor's staff, was actually

11      reproached by the inspector general?

12             It doesn't happen.

13             It just doesn't happen.

14             Now, maybe they're all behaving appropriately

15      all the time and there's no ethical transgression.

16             I think the record of the last two years has

17      shown that that would not hold up to scrutiny, that

18      statement.

19             But, even assuming that it was, the structure

20      is not one that promotes confidence that the

21      watchdog is actually watching.

22             SENATOR KRUEGER:  Thank you.

23             Thank you.

24             SENATOR BIAGGI:  Okay.

25             So, Senator Palumbo.







                                                             193
 1             SENATOR PALUMBO:  Thank you, Madam Chair.

 2             How are you?

 3             ROBERT H. TEMBECKJIAN:  I'm very well, thank

 4      you, Senator.

 5             Nice to see you again.

 6             SENATOR PALUMBO:  Nice to see you as well.

 7             You know, it's solidifying in my head,

 8      I think, what this right model is, and you are

 9      obviously a representative of that.

10             I think, incrementally, we're getting there

11      in the legislature.  We're certainly not there yet,

12      but the education and training seems to be the

13      point.

14             And that almost segues into the upstate judge

15      who said don't preside over any legislator.

16             ROBERT H. TEMBECKJIAN:  Right.

17             SENATOR PALUMBO:  Since you have, and you may

18      have seen that we had Senator Wiener from California

19      on, the chair of their ethics committee, and they

20      have, various levels of punishment, and that, from

21      the public's point of view, seems to be critical.

22             Because -- and I just -- of course, I'm

23      making kind of general comments, but I will have a

24      question, or maybe if you want to just expound upon

25      it.







                                                             194
 1             That that judge, yes, he said, well, I said

 2      maybe it was improper and inappropriate for me to

 3      say that.  I apologize.  I was in a bad mood that

 4      day.  You know, the dog, whatever, got lost, but you

 5      still censured him.

 6             ROBERT H. TEMBECKJIAN:  Yes.

 7             SENATOR PALUMBO:  And that's almost a really

 8      important point, in my opinion.

 9             I'm a former prosecutor.  I'm the son of a

10      homicide detective.  When I got my -- I came right

11      out of law school, went -- DA's office.  Actually

12      worked right around the corner for a little bit for

13      [indiscernible].  And he said, You've got to have

14      compassion.

15             Like, there's a balance there.

16             But I think, from the public standpoint, you

17      don't either just hammer someone.  You can say,

18      Look, yeah, it was wrong, and, yeah, you apologized,

19      but you should know better.

20             ROBERT H. TEMBECKJIAN:  Right.

21             SENATOR PALUMBO:  And your training tells you

22      you can't say things like that.  And don't take the

23      position if you're not going take it seriously

24      enough to control your mouth.

25             So I think that is a very important aspect of







                                                             195
 1      it.

 2             And then, when we have, and this is really --

 3      let me ask just one quick question before I get to

 4      my second point.

 5             It's just a majority vote of the commission

 6      renders the punishment?  Or is it, basically,

 7      deliberated upon, and then they come out with

 8      something?

 9             How does that work; what's the process?

10             ROBERT H. TEMBECKJIAN:  Well, we have a

11      couple of different levels of quorum-and-vote

12      requirement.

13             This will be in stark contrast to the way

14      JCOPE is currently organized, but, to authorize an

15      investigation, it takes a simple majority of the

16      commission members, without regard to whether judge

17      members are for or against the investigation.

18             And, the commission has the statutory

19      authority to delegate to a panel of at least three

20      members the authority to investigation.

21             So as opposed to JCOPE, where two out of the

22      dozen or so commission members can thwart an

23      investigation, on our 11-member commission, 2 of

24      them can actually authorize one.

25             Now, what we have done as a practical matter







                                                             196
 1      over the years, is to make sure that every

 2      commission member gets every complaint that comes

 3      in.  And that's between 1500 and 2,000 a year.

 4             And every commission member votes on every

 5      complaint.

 6             But it's a simple majority that's required to

 7      authorize investigation, in order to -- so that's

 8      six out of eleven.

 9             In order to publicly discipline a judge, it

10      requires a quorum of eight members, so at least

11      eight have to be present and participating.  But it

12      still requires six votes to discipline.  So it's a

13      majority of the whole number regardless of however

14      many were actually participating in the case.

15             And sometimes, you know, a member is going to

16      be disqualified from a matter because they know the

17      individuals involved, or there is some other

18      disqualifying interest.

19             But it's a simple majority to investigate,

20      and an absolute majority to publicly discipline.

21      And that's worked very well over the years.

22             SENATOR PALUMBO:  It almost seems like you

23      would rather have more investigations, because it's

24      simply an investigation, than less.

25             Because, with that JCOPE example, with the







                                                             197
 1      leak, that it was just suppressed and squashed, that

 2      it just was so flagrant and offensive to everyone.

 3             That's something that I think we're dealing

 4      with at this point:  It's just the public

 5      perception, is that whatever we do isn't going to

 6      fix anything anyway.  It will be the same old, same

 7      old.

 8             And that's what we're looking to avoid.

 9             ROBERT H. TEMBECKJIAN:  Well, I think that's

10      exactly right.  Investigation is not discipline.

11      It's not a finding of wrongdoing.  It is a

12      collection of the facts in order to determine

13      whether or not somebody has violated the rules and

14      should be punished for it.

15             And the majority of our investigations result

16      in no action against the judge.

17             We -- I mean, we might -- we discipline

18      20 judges a year, but we investigate 150 complaints,

19      200 complaints.  We do initial inquiries on about

20      four or five hundred out of the 1500 or 2,000 that

21      we get.

22             As you might imagine, a lot of the complaints

23      we get are just from people who are unhappy that

24      they lost, and they blame the judge, and it's not

25      really ethical misconduct.







                                                             198
 1             And in that way, we actually protect the

 2      independence of the judiciary, because we absorb a

 3      lot of the anger of the litigating public that went

 4      to court and lost, and who can't believe that on the

 5      merits they lost, so the judge must be corrupt.

 6             We absorb that criticism so it's not directed

 7      at the judiciary.

 8             We explain to each complainant why their

 9      complaint was dismissed; or, in the cases where we

10      take action, what prompted us to take action.

11             And I would say that the nicest letters that

12      we get, although there aren't all that many of them

13      every year --

14             SENATOR PALUMBO:  I know your pain.  We all

15      know your pain.

16             ROBERT H. TEMBECKJIAN:  -- are from

17      complainants who say, Thank you.  I appreciate that

18      you looked at it, and you have explained to me why

19      the judge didn't do anything wrong.  And I feel

20      satisfied that at least I was heard.

21             And that's an important function that ethics

22      enforcement entities play.

23             It's not just that they get the bad guys who

24      did it wrong and who deserve to be disciplined, but

25      it helps to underscore for the public that there's







                                                             199
 1      actually somebody out there paying attention to

 2      their grievances, and explaining to them why, well,

 3      in this case, it really doesn't amount to something

 4      that should lead -- criticism or the discipline of a

 5      public official.

 6             SENATOR PALUMBO:  Sure, sure.

 7             And just, lastly, do you -- can you issue

 8      subpoenas?

 9             ROBERT H. TEMBECKJIAN:  Yes.  The commission

10      can issue subpoenas in our statute.  As the

11      administrator I can issue subpoenas.

12             And when we refer a matter to a disciplinary

13      hearing, which my staff presents the case against

14      the judge and the judge defends, the hearing officer

15      can issue trial subpoenas.

16             So subpoena power obviously is extremely

17      important, not only to compel testimony, but to

18      collect documents, because a lot of our cases, and a

19      lot of yours, would, essentially, be

20      document-driven; memoranda that are made, disclosure

21      statements that are filed that might not be complete

22      or accurate.

23             There's all kinds of documentation in these

24      cases.  And without the authority to get those

25      records, no investigation could really be thorough,







                                                             200
 1      or comprehensive.

 2             SENATOR PALUMBO:  Exactly.  And I think

 3      that's probably an extremely important point that,

 4      even with JCOPE, they couldn't even authorize a

 5      subpoena to ultimately get into, you know, for

 6      example, the leak information.

 7             That's an easy one.  That should take you

 8      about 20 minutes to figure out how to solve that

 9      one.  And it was [simultaneous talking;

10      indiscernible] --

11             ROBERT H. TEMBECKJIAN:  Well, yeah, I mean,

12      I think anybody watching would have known who needed

13      to be interviewed by the investigators.

14             And to say, as I've heard, that, well, the IG

15      or JCOPE, you know, the IG can't investigate the

16      governor.

17             But interviewing the governor about someone

18      else's misconduct is not investigating the governor.

19             If the allegation is that someone from JCOPE

20      leaked to the governor, you ask the person who got

21      the call, "Who made the call?"

22             You're not in trouble for having picked up

23      the phone, but the person that dialed is.

24             So it wouldn't have been investigating the

25      governor, to ask him, Who called you and told you







                                                             201
 1      what the JCOPE confidential vote was?

 2             SENATOR PALUMBO:  Sure.

 3             ROBERT H. TEMBECKJIAN:  And we all know it

 4      didn't happen.

 5             SENATOR PALUMBO:  Right.

 6             Thank you, and happy holidays.

 7             Thank you for coming.

 8             ROBERT H. TEMBECKJIAN:  Thank you.  Same to

 9      you.  Thank you.

10             SENATOR BIAGGI:  Thank you.

11             Senator Hoylman.

12             SENATOR HOYLMAN:  Thank you, Madam Chair.

13             And thank you for this hearing, for the

14      second hearing, really important, and an important

15      time to do this.

16             I want to ask you a few questions.

17             So the makeup of your commission is, between

18      the governor and the chief judge, seven

19      appointments?

20             ROBERT H. TEMBECKJIAN:  Correct.

21             SENATOR HOYLMAN:  And which is a majority of

22      the 11 appointees.  The members of the legislature,

23      each conference only has one appointee.

24             So not unlike JCOPE, to some extent, or the

25      commission on judicial appointments, between the







                                                             202
 1      governor and OCA, they have controlling authority.

 2             Any concern about that?

 3             ROBERT H. TEMBECKJIAN:  Well, it hasn't been

 4      a problem for us, and I think it's because there

 5      have been -- there are two other built-in

 6      safeguards.

 7             One is, that the appointing authorities make

 8      their appointments for four-year terms, and they're

 9      staggered.

10             So no appointing authority can appoint more

11      than one member in any given year.  It would take

12      four years for there to be a complete turnover.

13      When a new governor, for example, comes in, and if

14      the new governor is inclined to turn over

15      employees -- or, members from the predecessor, it

16      would take four years to effect that kind of change.

17             SENATOR HOYLMAN:  Well, we've seen a

18      three-term governor who ended up having almost total

19      control over --

20             ROBERT H. TEMBECKJIAN:  Right.

21             SENATOR HOYLMAN:  -- [simultaneous talking]

22      commissions, authorities, and [simultaneous

23      talking] --

24             ROBERT H. TEMBECKJIAN:  Well, with us,

25      because --







                                                             203
 1                [Simultaneous talking.]

 2             ROBERT H. TEMBECKJIAN:  -- because the

 3      governor appoints only four out of the eleven,

 4      doesn't appoint the chair and doesn't appoint the

 5      chief executive officer, it takes a while to change

 6      the orientation, let's say, if there is going to be

 7      some view that the commission needs to change

 8      because a governor wants to get it under his or her

 9      control.

10             SENATOR HOYLMAN:  And on the other side of

11      the coin, it's going to take a while to untangle,

12      you know, control if it's vested for, you know,

13      12 years, or something approaching that.

14             ROBERT H. TEMBECKJIAN:  Well, that might be

15      so.

16             But our experience over 40 years has been

17      that governors have come and gone.

18             Chief judges and legislative-appointing

19      authorities have come and gone.

20             But in 45 years, since the commission was

21      first a temporary entity, and then codified in the

22      state constitution, I'm only the second chief

23      executive officer.

24             We have had enormous success I think, in

25      part, because we have had stability.







                                                             204
 1             The day-to-day operation of the entity is by

 2      professionals whose work is in this highly

 3      specialized field of judicial ethics enforcement.

 4             It's not subject -- easy whim of one or two

 5      appointing authorities to change.

 6             And because our budget is not controlled by

 7      the judiciary, the chief judge can't make that

 8      effect, or have that effect.

 9             And because the governor appoints only four

10      out of eleven, doesn't appoint the chair, the chief

11      executive officer, the governor doesn't have that

12      power either.

13             The way that we can be inhibited is by

14      budgetary constraint.

15             And that's where you and I, and

16      Senator Krueger and I, have our annual conversation

17      about the division of budget, you know, essentially,

18      trying to freeze us out.  Not out of malice.

19      I think it's just because that's the way they

20      operate.

21             Their mandate is "no."

22             Say no.

23             Say no, say no, say no.

24             And ours is, we have a constitutional role to

25      play, you can't do this on a pittance.







                                                             205
 1             It requires attorneys, investigators,

 2      administrative staff.  It requires physical

 3      structure.

 4             SENATOR HOYLMAN:  Well, on that note -- on

 5      that note, what is, I agree, the resource question

 6      goes -- heart of your ability to be independent.

 7             ROBERT H. TEMBECKJIAN:  Right.

 8             SENATOR HOYLMAN:  What is the preview that

 9      Senator Krueger is going to be receiving in the

10      [indiscernible] year?

11             ROBERT H. TEMBECKJIAN:  Well, our current

12      budget, after years of division of budget

13      recommending flat, and your adding to it, we're at

14      about 6.5 million.  And I'm asking for just under

15      7.2.

16             We are authorized to have 50 full-time

17      employees, but we only have the funding now for 43.

18             I'd like to get that up.

19             And a couple years ago we were down to 38.

20      But because of the additional funding that you

21      provided, we were able to incrementally get that up

22      to 43.

23             We run a statewide operation.  We've have

24      three offices.  There are 3400 judges spread out

25      through over 1200 courts in New York State.  It's







                                                             206
 1      physically challenging.

 2             And in the last two years, year and a half,

 3      we have spent a lot of resources on an electronic

 4      virtual mode of operating because of COVID.

 5             And I think that we will probably stick with

 6      that even after the COVID experience is far enough

 7      behind us, to be able to go back to work without

 8      masks and in greater proximity to one another.

 9             But it takes money to do that.

10             SENATOR HOYLMAN:  Yeah, I went to your

11      website again.  Yeah, I do look at it.

12             ROBERT H. TEMBECKJIAN:  I know you do.

13             I can tell by the questions you're asking me

14      here.

15             SENATOR HOYLMAN:  By the way, you need to

16      update the new minority leader for the Senate.  It

17      still lists John Flanagan.

18             But --

19             ROBERT H. TEMBECKJIAN:  Well, but the

20      appointee was made by Senator Flanagan.

21             SENATOR HOYLMAN:  Oh.  So you wouldn't change

22      that?

23             ROBERT H. TEMBECKJIAN:  Right, until the next

24      appointment.  So his term is up, and then the new --

25             SENATOR HOYLMAN:  It's still, even though --







                                                             207
 1      okay.

 2             ROBERT H. TEMBECKJIAN:  -- yeah.

 3             SENATOR HOYLMAN:  -- okay.  That's

 4      interesting.

 5             ROBERT H. TEMBECKJIAN:  He is an appointee of

 6      Senator Flanagan.  And I think it was --

 7             SENATOR HOYLMAN:  So he remains.  And the new

 8      appointee doesn't --

 9             ROBERT H. TEMBECKJIAN:  Correct.  Right.

10             SENATOR HOYLMAN:  Okay.

11             ROBERT H. TEMBECKJIAN:  When the appointing

12      authority changes, the members that that appointing

13      authority put on, don't.  They serve four-year

14      terms --

15             SENATOR HOYLMAN:  They serve four.  Okay.

16             That's a good point.

17             ROBERT H. TEMBECKJIAN:  -- under the

18      constitution, which is another protection.

19             SENATOR HOYLMAN:  Thank you.

20             So in terms of transparency, do you think

21      that the public should be entitled to the

22      transcripts of your hearings?

23             ROBERT H. TEMBECKJIAN:  Oh, well, if the --

24      if a public discipline has been imposed, the public

25      is entitled to it.







                                                             208
 1             SENATOR HOYLMAN:  But what if a public

 2      discipline isn't imposed?

 3             ROBERT H. TEMBECKJIAN:  If a public

 4      discipline is not imposed --

 5             SENATOR HOYLMAN:  Why should it be in a black

 6      box?

 7             I mean, it's like every other -- there are so

 8      many analogies of where hearings, whether they're

 9      decided for or against the defendant are made

10      public.

11             Why in this case are they protected?

12             And certainly legislators would be subject to

13      that kind of scrutiny.

14             ROBERT H. TEMBECKJIAN:  Right.  And you know

15      that I agree with you.

16             The -- we have proposed, in fact, when

17      Judith Kay was the chief judge, she actually -- she

18      actually proposed, legislation that would have made

19      commission proceedings public at the point that a

20      judge is formally served with charges, which means

21      that the transcript of the proceeding, whatever the

22      result, would be public.

23             That's a matter for the legislature.

24             The legislature did not adopt that

25      legislation when Judge Kay proposed it.







                                                             209
 1             And although there are, you know, periodic

 2      discussions about reviving it, it really hasn't

 3      picked up any traction since.

 4             SENATOR HOYLMAN:  Well, look in 2022, I think

 5      we're going to be looking to revive that.

 6             ROBERT H. TEMBECKJIAN:  Well, that would be

 7      very interesting.

 8             And as long as you're going to be doing that,

 9      let me recommend something else for us, that would

10      actually also be apropos for a legislative or

11      executive ethics, which is that resignation from

12      office under investigation should not end the

13      inquiry by the body.

14             If you have engaged in ethical misconduct,

15      and it would ordinarily or otherwise deserve public

16      discipline, you shouldn't be able to avoid it by

17      leaving office.

18             Under current law, we have only 120 days

19      after a judge resigns to impose discipline, but the

20      only discipline we can impose under law in that case

21      is removal from office; the reason being, that

22      removal under the constitution also bars you from

23      ever being a judge again.

24             But if you have done something censurable or

25      admonishable, why should you be able to evade the







                                                             210
 1      consequences of that by resigning and thwarting the

 2      body because we lose jurisdiction at that point.

 3             SENATOR HOYLMAN:  Particularly if that

 4      investigation might lead to exposure, an

 5      understanding, of criminal misconduct.

 6             ROBERT H. TEMBECKJIAN:  Well, yes, we do have

 7      the authority to make referrals, and we often do, to

 8      district attorneys or U.S. attorneys.  But that's

 9      not a public act.

10             And if they don't take action, then the

11      public is never going to know.

12             And the same is true, by the way, of

13      referrals that we make -- attorney grievance

14      committees, because there are occasions when we come

15      across what appears to be misconduct by lawyers.

16             We don't have jurisdiction over them.  We

17      refer them to the grievance committees.  Those

18      proceeding are confidential.  And sometimes they go

19      into, you know, the black hole of disciplinary space

20      and nobody knows what happened, least of all the

21      clients who might be adversely affected by a lawyer

22      who should be disciplined.

23             SENATOR HOYLMAN:  Well, thank you for your

24      excellent work.

25             Thank you, Madam Chair.







                                                             211
 1             ROBERT H. TEMBECKJIAN:  Thank you.

 2             SENATOR BIAGGI:  Thank you very much.

 3             And just one comment from Senator Palumbo,

 4      and then I will close this out.

 5             SENATOR PALUMBO:  Yes, thank you.

 6             I just want to follow up on

 7      Chairman Hoylman's comments regarding disclosing.

 8             Did you say that was -- that the legislation

 9      was to disclose from Judge Kay at the time of the

10      complaint or time of finding?

11             ROBERT H. TEMBECKJIAN:  Not the original

12      complaint.  At the time that the commission

13      authorizes formal disciplinary charges against the

14      judge.

15             So it would be after investigation, but

16      before discipline; not the initial complaint.

17             I think there would potentially be great

18      damage to the judiciary to unfairly sully a judge

19      simply by making public the filing of a complaint,

20      which could be politically motivated, it could be

21      personally motivated.

22             In the same way that a grand jury

23      investigation is confidential, commission

24      complaints, or -- to the commission, and our

25      investigations, I think must be confidential, and







                                                             212
 1      also to protect the integrity of the investigation.

 2             I mean, we don't necessarily want everybody

 3      knowing when we're investigating, so that we can be

 4      assured of getting honest and fair responses to our

 5      inquiries not coached by people who know we're

 6      coming, necessarily.

 7             But if the commission, as a responsible body,

 8      concludes at the end of an investigation that

 9      there's reason to believe that misconduct has

10      occurred, but can't impose discipline until the

11      judge is charged and has a trial, that should -- in

12      my view, that should be public just like an

13      indictment is public.

14             SENATOR PALUMBO:  Sure.  And that was exactly

15      what jumped out at me, because you mentioned earlier

16      that attorneys, similar to appointees by the

17      governor, are afraid to come forward and actually

18      say something.

19             So if you know that a judge upstate, for

20      example, that you practice in front of on a weekly

21      basis or more, you're not going to really give that

22      judge up because, if it doesn't go -- if he's not

23      removed or she is not removed, you have a big

24      problem now.

25             ROBERT H. TEMBECKJIAN:  And that's exactly







                                                             213
 1      right.

 2             SENATOR PALUMBO:  And that's why I think that

 3      would be -- and I'm sure we'll debate this.  I'm on

 4      the judiciary committee with the chairman as well,

 5      that as those come through, that I think there's got

 6      to be that threshold first; otherwise, your

 7      investigation will -- can be spoiled.

 8             ROBERT H. TEMBECKJIAN:  Well, you know, there

 9      are any number of times in a year when we'll get a

10      phone call from a lawyer who will say, I've seen

11      misconduct I think by a judge, but is there a way

12      that I can report it without being the complainant?

13             And the fact that, under law, our commission

14      has the authority to investigate or initiate

15      complaints on its own motion, it doesn't have to be

16      a third-party complaint that we get from someone

17      else, is also a very important structural feature

18      that should be built into any ethics enforcement

19      operation, so that I can take that information from

20      the lawyer on the telephone, reduce it in writing,

21      present it -- commission, and say, This individual

22      indicated to us what certainly seems to be

23      misconduct if it's true, but is afraid to be the

24      complainant.

25             So I'm asking the commission to authorize







                                                             214
 1      inquiry on its own, and it will do so.

 2             And then, under our statute, I reduce the

 3      complaint itself in writing so that, when it's

 4      presented to the judge, the judge will know the

 5      four corners of what he or she is being accused of.

 6             But that's a very important feature: to give

 7      the investigating body some responsible way of

 8      initiating investigations on its own.

 9             SENATOR PALUMBO:  Which is perfectly relevant

10      to us with, you know, hostile work environments,

11      sexual harassment, and so forth.

12             So I think that makes sense.

13             ROBERT H. TEMBECKJIAN:  Well, I think so.

14             SENATOR PALUMBO:  Thank you again.

15             And now, that's it; so, now, happy holidays,

16      again.

17             Thank you.

18             ROBERT H. TEMBECKJIAN:  That's okay.

19             SENATOR BIAGGI:  Thank you.

20             I have just have a few follow-up questions,

21      and they're kind of themed, that draw the line

22      through what you're doing and the commission to

23      JCOPE.  And I think there's a lot of different

24      threads that I've learned.

25             I think the first thing, with regard to the







                                                             215
 1      complaints initially not being public, one of the

 2      things that happened in the last, you know, six to

 3      eight months was that the governor -- former

 4      governor threatened to release all of the complaints

 5      from JCOPE that people made about legislators, as a

 6      threat, which is absurd and, also, completely

 7      unprofessional.

 8             But I think it makes me wonder, and also

 9      think about, the differences between how complaints

10      are made, and you just touched on a really

11      significant piece.

12             But, also, when a complaint is made, is that

13      judge notified that a complaint has been made

14      against them?

15             Because in -- I mean, who knows what happens

16      in JCOPE -- quite literally, who knows what happens

17      in JCOPE.  I don't even think the people sometimes

18      inside know what's going on there.

19             But the reality is, there is some kind

20      notification that's kind of lacking in our current

21      ethical structure that we hope to take apart.

22             But as it stands, my understanding is that

23      it's really inconsistent.

24             So are the complaint -- are the complaints

25      made public -- not made public -- people, but --







                                                             216
 1      person who the complaint is being made against?

 2             ROBERT H. TEMBECKJIAN:  Not necessarily.

 3             We're not required to advise a judge of every

 4      complaint against him or her that has come in, and

 5      there are a couple of important reasons I think why

 6      that's significant, and why I wouldn't want to

 7      change that.

 8             First, if the complaint is true and we're

 9      going to investigate it, we don't necessarily want

10      the target, so to speak, or the subject of the

11      inquiry, to be able to influence witnesses before

12      we've had a chance to talk to them; or to create or

13      to lose documents before we've had a chance to

14      collect them.

15             But, secondly, and I think more

16      significantly, particularly for the judiciary, every

17      time a judge is going to run for reelection, or be

18      up for appointment, they have to fill out a waiver

19      of confidentiality as to any complaints about which

20      they are aware.  They have to fill out a form.

21             In fact, we actually removed a judge from

22      office, and it was held by the court of appeals,

23      because, on an application to the governor -- this

24      is back when Pataki was the governor -- he

25      omitted -- he answered falsely the question, "Have







                                                             217
 1      you ever been the subject of an investigation by an

 2      ethics body?" when, at that very time, he was under

 3      investigation by the commission.

 4             And when that came to light, the nomination

 5      was withdrawn, and, obviously, the judge/he was

 6      ultimately removed from office for lying on an

 7      affidavit or on a sworn form to the governor.

 8             But more often than not, since the majority

 9      of our complaints are dismissed without action

10      against the judge, if the judge knows about 20 or

11      30 complaints that have been made over the course of

12      a 10-year term, and then is applying for a new

13      position, or is filling out a screening committee

14      affidavit for endorsement for reelection, they're

15      going have to disclose all of those frivolous

16      complaints because they knew about them; whereas we

17      won't reveal them, and we might provide a letter --

18      judge that says, you know, You have never been under

19      investigation by the commission.  You have never

20      been found to be in violation of the rules.

21             But if the judge knows about it, they're

22      going have to disclose it.

23             And think about the havoc that you can create

24      by papering a judge with complaints so that you can

25      sully their reputation for when they run for







                                                             218
 1      reelection.

 2             We actually had -- one of the saddest

 3      situations that I ever came across in all these

 4      years involved a judge many years ago in

 5      Tompkins County, who was running for reelection.

 6      And it doesn't matter which political party the

 7      judge was running for.  The chair of the opposing

 8      party sent a letter of complaint -- commission about

 9      that judge, which was ultimately dismissed because

10      it was a frivolous complaint, but made public four

11      days before the election.  Over the weekend, a

12      complaint has been made -- judicial conduct

13      commission against Judge So-And-So, and they're

14      looking into it.

15             Well, yeah, we look at every complaint that

16      we get, but we didn't investigate that one.

17             But between Saturday, when this was

18      disseminated locally, and Tuesday's election, the

19      incumbent lost because of mischief, of malicious

20      mischief, I think, by a political party leader of

21      the other side.

22             So I'm not comfortable with the notion that

23      any complaint against a judge should be disclosed,

24      unless there has been some level of verification

25      that it is true.







                                                             219
 1             SENATOR BIAGGI:  So can I just distinguish

 2      something, because I think you bring back some

 3      unfortunate memories for some of us from 2016, when

 4      things are just made public, and then it really

 5      does -- it has an incredible -- can incredible

 6      impact about just -- about anything.

 7             But if you have one investigation -- and

 8      I agree with everything you've said, actually.

 9             And I'm wondering if there's a distinguishing

10      factor between that one complaint that's made, and

11      then -- point that you had made about the example

12      of, like, well, if this person had like 20 to 30 --

13      if there is an instance where a judge has 20 or 30,

14      or 15, or even 5 feels like a lot, to be honest, and

15      there is a consistent pattern of what is being

16      complained about from a different person, although,

17      in many instances, it could be, again, an attorney

18      that, because you -- that person wants to be

19      anonymous, and the body decides to do this

20      investigation on their own, you might not know who

21      it is, if it's the same person over and over again,

22      obviously, that's a different situation, but the

23      point being, if the person has a similar track of,

24      like, hey, this is kind of a theme going on here,

25      does the body then look closer?







                                                             220
 1             Like, what do you do in that kind of

 2      instance?

 3             ROBERT H. TEMBECKJIAN:  We try to evaluate

 4      each complaint on its own merits.  But we are

 5      certainly aware of cumulative complaints against the

 6      same judge.

 7             But we also do, I think, a very important

 8      analysis of the nature of the court, the nature of

 9      the complaints.

10             I mean, as an example, nobody who goes into

11      family court is ever happy, unless it's a simple

12      adoption and they walk out with their child.

13             Nobody is happy coming out of family court,

14      no matter who wins or loses.

15             And family court judges have, I think,

16      probably the most difficult job in the Unified Court

17      System, and everybody is going to complain against

18      them, because --

19             SENATOR KRUEGER:  Now they have blogs, where

20      they put their complaints on the blog.

21             ROBERT H. TEMBECKJIAN:  I know.  We've seen

22      it.

23             SENATOR KRUEGER:  I've had that where

24      constituents would be, you know, We all hate this

25      judge.  They didn't give you full custody.







                                                             221
 1             You know?

 2             ROBERT H. TEMBECKJIAN:  Right.  Right.

 3             -- so we try to do that kind of analysis.

 4             The same thing with a criminal court judge,

 5      who -- you know, who might be known as a tough

 6      sentencer; or, conversely, you know, a lenient

 7      sentencer.

 8             So there's always somebody.

 9             Police unions or district attorneys might

10      complain about the lenient sentencing judge, and

11      defendants and the families of defendants might

12      complain against the tough-sentencing judge.

13             We try to avoid investigating anybody for

14      calling the cases as they see them, unless there is

15      some element of misconduct involved, so that, if a

16      judge is a tough sentencer or a lenient sentencer,

17      but it's within the law, and they're abiding by the

18      law, they're following the law, that's not a matter

19      of ethical wrongdoing, and it shouldn't -- it

20      shouldn't impact our decision on whether to

21      investigate a new complaint against that a judge for

22      being a tough or a lenient sentencer.

23             On the other hand, if we have had numerous

24      complaints about a judge's irascibility on the

25      bench, and they seem to be coming from sources that







                                                             222
 1      have no connection to one another, it tends to lend

 2      some credence -- latest complaint, and we might be

 3      inclined to investigate it and then do our own

 4      observation, by going to court, sitting in the

 5      spectator section on random days to see what's going

 6      on.

 7             And, nowadays, we can actually order the

 8      audio of a court proceeding, and hear whether the

 9      judge was acting intemperately, using fowl language,

10      yelling unnecessarily, you know, flying off the

11      handle, and so forth.

12             And I must say that the advent of audio

13      recordings in the courts has had two effects.

14             It has demonstrated for us that, often,

15      complaints of judge's inappropriate demeanor are not

16      substantiated when we actually hear the audio.

17             But I also think the fact that they're being

18      recorded tends to serve as a check on their

19      demeanor, and the decorum of the court is preserved.

20             And so that's a good thing.

21             The tapes actually help the judges, but

22      I think their behavior is moderated because they

23      know they're being recorded.

24             SENATOR BIAGGI:  Makes sense.

25             That makes a lot of sense.







                                                             223
 1             Okay.

 2             Just three questions that are really short.

 3             The first one is, inside of the commission,

 4      do you have jurisdiction to look at all of the

 5      judges in New York?

 6             And I ask this specifically because, and this

 7      was a bill that Senator Hoylman had had, about how

 8      ICE agents can come in court.  And when we realized

 9      that OCA set these rules, that, basically, they were

10      not allowing ICE agents in court, it didn't actually

11      go down -- town and municipal level.

12             And so it creates this imbalance of, like,

13      how are the rules even applied if OCA can't tell

14      municipal judges what to do, and, like, where are we

15      going here?

16             So do all the judges fit within the purview

17      of the commission?

18             ROBERT H. TEMBECKJIAN:  Yes.

19             We have authority over all of the judges in

20      the Unified Court System.

21             If your judgeship is created in the

22      constitution, we have authority over you.  That's

23      from the town and village courts, all the way up to

24      the Court of Appeals.

25             SENATOR BIAGGI:  That's very good to know.







                                                             224
 1             Okay.  Thank you for that.

 2             In terms of the referrals database --

 3      referrals -- not database, but in terms of the

 4      referrals that you make that are not perhaps within

 5      your purview -- right? --

 6             The comptroller's office made some similar

 7      comments about that -- right? -- something might not

 8      fall within their purview, they're going to send it

 9      out.

10             -- I seem to think that there is -- that

11      there's an importance about the tracking of this.

12             It might seem just like administer -- just an

13      administer -- excuse me -- an administrative detail

14      that's annoying and you don't want to deal with

15      that.  But somewhere along the way, you would

16      probably want to know where this thing originated

17      from, and who sent it where it was going.

18             And so is there -- you had mentioned the same

19      kind of process.

20             Does the commission also do that, or is

21      there -- do that, meaning, to be specific: keep a

22      database or not?

23             ROBERT H. TEMBECKJIAN:  No, we don't have a

24      database of that, although we do have a record of

25      every -- I should say, we don't have a separate







                                                             225
 1      database for the complaints that we have referred,

 2      but we do have a master database --

 3             SENATOR BIAGGI:  Got it.

 4             ROBERT H. TEMBECKJIAN:  -- of all of our

 5      complaints, including the dispositions, so that

 6      I can -- within that, manipulate the fields, to be

 7      able to determine how many referrals we've made in a

 8      given year.  And we report those in our annual

 9      report.

10             The ones that we ask for follow-up on are

11      complaints that we referred that might involve the

12      judge.

13             So let's say there's an administrative issue

14      that we become aware of involving a judge.  We refer

15      that -- Office of Court Administration, and we ask

16      them to report to us on what the result was.

17             And they will tell us:

18             We sat down with the judge, we gave her

19      education and training.

20             We gave him a copy of the manual.

21             Et cetera, et cetera.

22             If we are referring anything else over

23      individuals over whom we have no authority, we have

24      not, except out of curiosity, asked for follow-up.

25             With the grievance committees, because they







                                                             226
 1      regard the commission as the complainant when we

 2      make a referral, they will tell us, ultimately, the

 3      result of their inquiry.

 4             And that's how I know that a lot of the

 5      complaints that we send over there don't result in

 6      disciplining of attorneys, because they regard us as

 7      the complainant, and then they notify us that the

 8      complaint was dismissed, or there was no action

 9      taken against that individual.

10             But -- so that's the degree to which we do

11      that:

12             We follow up if it's a judge.

13             If it's to a grievance committee, they will

14      tell us what the result is because they regard to us

15      as the complainant.

16             And if it's anyone else, they're not obliged

17      to tell us, and we don't ask.

18             SENATOR BIAGGI:  Right.

19             Okay.  It makes lots of sense to me.

20             Final question, and then I believe that we

21      are concluding for the day.

22             When you mentioned that there's this

23      gradation of what you can do -- right? -- from --

24      with everything but suspension -- censoring,

25      removing, people can retire -- and then there was







                                                             227
 1      also the private conversations or private --

 2             ROBERT H. TEMBECKJIAN:  A private caution.

 3             SENATOR BIAGGI:  -- private caution --

 4      right? -- for like some minor violation --

 5             ROBERT H. TEMBECKJIAN:  Right.

 6             SENATOR BIAGGI:  -- suspension seems to fall

 7      within the middle -- right? -- of those two

 8      extremes.

 9             ROBERT H. TEMBECKJIAN:  Right.

10             SENATOR BIAGGI:  And so can you just give

11      like one example on each side of, like, what is an

12      example -- what is a private minor violation; how

13      can people think about that?

14             And then, also, because suspension is not

15      part of this repertoire, if suspension were to fit

16      in, what is an example of why somebody would be

17      suspended?

18             One example on each.

19             ROBERT H. TEMBECKJIAN:  In terms of a private

20      caution, let's say one of the rules of conduct is

21      that a judge is required to file an annual statement

22      of financial disclosure.

23             And if they're late, they get a notice to

24      cure, which gives them 30 days to file.  And if they

25      don't, then there's a notice of delinquency.







                                                             228
 1             It's required for the ethics commission to

 2      refer that to us.

 3             And if the judge was -- and we've had this

 4      situation -- the judge filed late because he was

 5      hospitalized, or because the judge's spouse was in

 6      hospice care, and there were a couple -- we send

 7      them a private letter.

 8             And, of course, only upon their actually

 9      filing, so they correct the violation.  But there's

10      no suggestion that they were withholding information

11      or not reporting income.

12             You know, we look at the compassionate view,

13      and conclude that that's really -- that's not a

14      public discipline.  There's a reasonable explanation

15      for why the judge was late.

16             Or, judges are expected to, you know, respect

17      and comply with the law.  And that means, among

18      other things, in town and village court, as

19      elsewhere, before someone testifies, you've got to

20      give them an oath.  And sometimes the judge forgets

21      to give the oath, because it's sort of an informal

22      setting, even though it's a court proceeding.  But

23      it's not a habit, and no rights were affected.

24             And so we'll just sort of privately remind

25      the judge, Remember to administer the oath before







                                                             229
 1      you take a statement from the witnesses.

 2             On the opposite side, where suspension --

 3      suspension is, you know, there is some behavior that

 4      is worse than a censure, but not really quite

 5      removable, particularly if the judge acknowledges or

 6      recognizes the wrongdoing and is making some effort

 7      to improve.

 8             So let's say we -- you know, we had a case

 9      some years ago of a judge who was using a court

10      staff -- we had a couple of cases of this type -- a

11      judge who was using court staff to do personal

12      chores for the judge beyond the norm.

13             I mean, we're not talking about calling to

14      make a reservation at a restaurant.

15             But having, you know, a staff member pick up

16      the judge's dry cleaning, or do some -- type the

17      resume for the judge's spouse, or watch the judge's

18      child in court after school or in chambers after

19      school on more than an emergency basis.

20             We had another judge who had used her staff

21      to produce material for the judge's religious

22      institution, for a retreat that was -- a religious

23      retreat.  And they felt coerced to do it because

24      they owe their job -- judge.  And if the judge says,

25      you know, My religious institution is having a







                                                             230
 1      retreat, and I want to you make these booklets for

 2      me, and, you know, I would like you to attend if

 3      you'd like to attend, you kind of can't say no.

 4             That's a serious violation.

 5             But, in both instances, the judge

 6      acknowledged, when confronted by the commission,

 7      "That I really shouldn't have done that, it was

 8      really wrong, and I will never do that again,"

 9      I would have recommended suspension if we had that

10      authority.

11             But because the judge was contrite, and

12      otherwise was making an effort, the commission and

13      I agreed that censure was the right result.

14             So it's out there for other judges to know

15      you can't do this, and there is a consequence.

16             No judge likes to be censured.

17             You might be relieved that you weren't

18      removed.  But the opprobrium of your colleagues and

19      the public disgrace is not something that any judge,

20      or any public official, is going to welcome or brush

21      off.  And so it was a tough hit.

22             But that's the kind of thing where I think

23      suspension would have been an appropriate result:

24             Give them time to really reflect on what they

25      did, and when they come back, they'll be better.







                                                             231
 1             SENATOR BIAGGI:  I think that makes a lot of

 2      sense, actually.

 3             So I think we have a lot of work to do after

 4      today.

 5             Thank you so much for your testimony, for

 6      showing up today.

 7             I certainly learned a lot about what your

 8      commission does, and also how it can parallel track

 9      what we do when we build our new ethics body.

10             And, also, just how you go about certain

11      things, I think, is very enlightening to how we can

12      also internally do a lot of things as well.

13             So thank you very much.

14             ROBERT H. TEMBECKJIAN:  Well, I'm glad to be

15      of help.

16             And I hope when I see you all at budget time,

17      it's with a smile on my face instead of a hat in my

18      hand.

19                [Laughter.]

20             ROBERT H. TEMBECKJIAN:  Thank you very much.

21             SENATOR BIAGGI:  Thank you.

22             And that concludes our hearing.

23             So thank you all for joining.

24             Thank you for attending, asking questions,

25      and participating.







                                                             232
 1             I really do look forward to this becoming

 2      legislation, and, hopefully, the law.

 3             So, let's -- to onwards and really positive

 4      things in the future.

 5             Thank you.

 6                (Whereupon, at approximately 2:00 p.m.,

 7        the public hearing held before the New York State

 8        Senate Standing Committee on Ethics and Internal

 9        Governance concluded, and adjourned.)

10                            --oOo--

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25